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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SC upheld the COFEPOSA detention orders, holding that the detenus had no enforceable right to legal representation before the Advisory Board where the detaining or sponsoring authorities did not appear through counsel, and mere production of records by officers was not participation. It further found substantial compliance with the duty to supply relied upon material, as the pen drive contents were shown in prison and the relied upon documents, including translations, were furnished. The Court also accepted that communications rejecting the representations were ministerial acts conveying decisions already taken by competent authorities. Adequate subjective satisfaction, a live and proximate nexus, and the likelihood of release on bail were also established, so both petitions were dismissed.
SC upheld the COFEPOSA detention orders, holding that the detenus had no enforceable right to legal representation before the Advisory Board where the detaining or sponsoring authorities did not appear through counsel, and mere production of records by officers was not participation. It further found substantial compliance with the duty to supply relied upon material, as the pen drive contents were shown in prison and the relied upon documents, including translations, were furnished. The Court also accepted that communications rejecting the representations were ministerial acts conveying decisions already taken by competent authorities. Adequate subjective satisfaction, a live and proximate nexus, and the likelihood of release on bail were also established, so both petitions were dismissed.
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