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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Vagueness of the show cause notice and breach of natural justice were held decisive: the Order in Original relied on material and findings beyond the scope of the notice without specifying how that material prima facie established contraventions of the Customs Brokers Licensing Regulations, thereby offending principles of natural justice. The Tribunal's finding that the order travelled beyond the notice was sustained. Because the issue was procedural and factual, no substantial question of law arose for appellate review under the statutory appeal provision, and the appeal was dismissed.
Vagueness of the show cause notice and breach of natural justice were held decisive: the Order in Original relied on material and findings beyond the scope of the notice without specifying how that material prima facie established contraventions of the Customs Brokers Licensing Regulations, thereby offending principles of natural justice. The Tribunal's finding that the order travelled beyond the notice was sustained. Because the issue was procedural and factual, no substantial question of law arose for appellate review under the statutory appeal provision, and the appeal was dismissed.
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