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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Provisional release of imported in-shell walnuts was challenged on grounds that detention and conditional release were arbitrary and lacked tangible material. The court found no search or incriminating documents relating to the petitioner, noted prior statutory assessment and full payment of customs duty, and held that generalized allegations tied to others cannot justify seizure or coercive conditions such as bonds or guarantees. The court treated deprivation of property and equality concerns as engaging constitutional protection and exercised writ jurisdiction, concluding the detention was arbitrary and ordering relief consistent with provisional release while quashing unwarranted coercive conditions imposed without lawful basis.
Provisional release of imported in-shell walnuts was challenged on grounds that detention and conditional release were arbitrary and lacked tangible material. The court found no search or incriminating documents relating to the petitioner, noted prior statutory assessment and full payment of customs duty, and held that generalized allegations tied to others cannot justify seizure or coercive conditions such as bonds or guarantees. The court treated deprivation of property and equality concerns as engaging constitutional protection and exercised writ jurisdiction, concluding the detention was arbitrary and ordering relief consistent with provisional release while quashing unwarranted coercive conditions imposed without lawful basis.
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