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 goods was allowed against a bank guarantee securing differential duty where petitioners claimed preferential tariff treatment under CAROTAR and supplier furnished origin confirmations and cooperation; HC found no adjudicatory proceedings initiated and no conclusive adverse material since 2018, so denial of provisional release was unjustified. The court reasoned that potential departmental recovery of full customs duty would be adequately secured by the bank guarantee and that verification of origin can proceed without continuing detention; writ petitions disposed granting relief for provisional release.
Provisional release of imported goods was allowed against a bank guarantee securing differential duty where petitioners claimed preferential tariff treatment under CAROTAR and supplier furnished origin confirmations and cooperation; HC found no adjudicatory proceedings initiated and no conclusive adverse material since 2018, so denial of provisional release was unjustified. The court reasoned that potential departmental recovery of full customs duty would be adequately secured by the bank guarantee and that verification of origin can proceed without continuing detention; writ petitions disposed granting relief for provisional release.
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