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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Mandatory BIS registration for specified electrical imports was held to be a procedural requirement whose superseding Quality Control Order operates prospectively, so there was no retrospective obligation at import; the superseding order deferred registration and expressly excluded prior acts. Because the breach was procedural and there was no mens rea by the importer, confiscation and penalty were deemed unwarranted. The operative relief ordered was payment of a redemption fine of Rs. 15,000 and release of the goods on payment within one week of receiving the certified order.
Mandatory BIS registration for specified electrical imports was held to be a procedural requirement whose superseding Quality Control Order operates prospectively, so there was no retrospective obligation at import; the superseding order deferred registration and expressly excluded prior acts. Because the breach was procedural and there was no mens rea by the importer, confiscation and penalty were deemed unwarranted. The operative relief ordered was payment of a redemption fine of Rs. 15,000 and release of the goods on payment within one week of receiving the certified order.
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