Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Confiscation of gold jewellery lacked required procedural safeguards and statutory notices, so the State held a duty to preserve seized property intact as a bailee pending final adjudication; failure to follow seizure, inventory and disposal provisions and omission of prescribed notices vitiated the confiscation, entitling the owner to return or compensation. Where re-export is ordered but goods are no longer available, the operative effect is payment of present market value rather than value at seizure. Arbitrary detention and non-compliance with due process breached property and reasonableness guarantees.
Confiscation of gold jewellery lacked required procedural safeguards and statutory notices, so the State held a duty to preserve seized property intact as a bailee pending final adjudication; failure to follow seizure, inventory and disposal provisions and omission of prescribed notices vitiated the confiscation, entitling the owner to return or compensation. Where re-export is ordered but goods are no longer available, the operative effect is payment of present market value rather than value at seizure. Arbitrary detention and non-compliance with due process breached property and reasonableness guarantees.
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