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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Seizure of consignments by the surveillance team violated the Standard Operating Procedure applicable during the Model Code of Conduct; consequently the handover to Revenue was vitiated and the High Court's finding to that effect is sustained, with release directed to Sequel Logistics as the person from whom the goods were seized. A notice issued in reassessment proceedings against the courier employee was arbitrary because he was a custodian not shown to be owner, and was quashed. Third party ownership claims must be pursued under the statutory requisition/claim procedure rather than by writ.
Seizure of consignments by the surveillance team violated the Standard Operating Procedure applicable during the Model Code of Conduct; consequently the handover to Revenue was vitiated and the High Court's finding to that effect is sustained, with release directed to Sequel Logistics as the person from whom the goods were seized. A notice issued in reassessment proceedings against the courier employee was arbitrary because he was a custodian not shown to be owner, and was quashed. Third party ownership claims must be pursued under the statutory requisition/claim procedure rather than by writ.
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