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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CBDT circular timelines require prompt release of seized assets on furnishing adequate security, with special emphasis on jewellery due to valuation volatility; delays beyond the circular's 15 day period are arbitrary if unexplained and cannot prejudice petitioners for market value increases during delay. The note prescribes release of 901.030 grams of jewellery to claimants upon cross affidavits: a non objecting affidavit from one party and ownership affidavits from claimants; other seized items are ordered released against an existing bank guarantee, subject to filing of ownership and no objection affidavits prior to release.
CBDT circular timelines require prompt release of seized assets on furnishing adequate security, with special emphasis on jewellery due to valuation volatility; delays beyond the circular's 15 day period are arbitrary if unexplained and cannot prejudice petitioners for market value increases during delay. The note prescribes release of 901.030 grams of jewellery to claimants upon cross affidavits: a non objecting affidavit from one party and ownership affidavits from claimants; other seized items are ordered released against an existing bank guarantee, subject to filing of ownership and no objection affidavits prior to release.
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