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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Detention of perishable goods could not be left pending for months without a formal seizure order or timely action under the statutory detention framework. The High Court required the authorities to determine ownership on the basis of the accompanying invoices and the applicable departmental clarification, under which the consignor or consignee is treated as the owner where the prescribed documents accompany the consignment. It also rejected the insistence on the petitioner's personal appearance, holding that representation through an advocate is permitted in GST proceedings. The matter was directed to be heard immediately, with liberty to deposit the amount under Section 129(1)(a) and for release to follow in accordance with law if payment was accepted.
Detention of perishable goods could not be left pending for months without a formal seizure order or timely action under the statutory detention framework. The High Court required the authorities to determine ownership on the basis of the accompanying invoices and the applicable departmental clarification, under which the consignor or consignee is treated as the owner where the prescribed documents accompany the consignment. It also rejected the insistence on the petitioner's personal appearance, holding that representation through an advocate is permitted in GST proceedings. The matter was directed to be heard immediately, with liberty to deposit the amount under Section 129(1)(a) and for release to follow in accordance with law if payment was accepted.
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