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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The HC directed provisional release of goods and conveyance during pending revisional proceedings after noting that the first appellate authority had already modified the confiscation order and imposed liability under Section 129(1)(a), which the petitioner had satisfied. Because the revision had not yet resulted in a final order reviving action under Section 130, release was allowed but subject to revenue protection. The petitioner was required to furnish an indemnity bond and remain bound by the undertaking already filed, while the revenue retained liberty to enforce the revisional outcome. The merits of the revision were left open for the revisional authority.
The HC directed provisional release of goods and conveyance during pending revisional proceedings after noting that the first appellate authority had already modified the confiscation order and imposed liability under Section 129(1)(a), which the petitioner had satisfied. Because the revision had not yet resulted in a final order reviving action under Section 130, release was allowed but subject to revenue protection. The petitioner was required to furnish an indemnity bond and remain bound by the undertaking already filed, while the revenue retained liberty to enforce the revisional outcome. The merits of the revision were left open for the revisional authority.
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