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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Provisional release of seized imported goods was directed on conditional terms, because the matter was at the seizure-memo stage and the relief sought was only interim release. The Court followed the earlier course adopted in identical matters and noted that the Supreme Court had declined to interfere with conditional release while allowing adjudication to continue. Release was ordered subject to payment of the enhanced duty quantified, furnishing of bank guarantee, and maintenance of transaction details after release. The adjudicating authority was expressly left free to decide the proceedings independently on their own merits, without being influenced by the provisional release order.
Provisional release of seized imported goods was directed on conditional terms, because the matter was at the seizure-memo stage and the relief sought was only interim release. The Court followed the earlier course adopted in identical matters and noted that the Supreme Court had declined to interfere with conditional release while allowing adjudication to continue. Release was ordered subject to payment of the enhanced duty quantified, furnishing of bank guarantee, and maintenance of transaction details after release. The adjudicating authority was expressly left free to decide the proceedings independently on their own merits, without being influenced by the provisional release order.
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