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 seized imported goods at the interim stage of seizure memo proceedings, treating the request as confined to conditional release pending adjudication. Noting that similar writ petitions on identical facts had already been allowed on the same basis and that course had been left undisturbed by the Supreme Court, the Court ordered release subject to payment of the enhanced duty quantified by Customs, furnishing of a bank guarantee, and maintenance of transaction details for any onward sale. The order expressly preserved Customs' to proceed with adjudication independently and to decide the matter in accordance with law.
The HC directed provisional release of seized imported goods at the interim stage of seizure memo proceedings, treating the request as confined to conditional release pending adjudication. Noting that similar writ petitions on identical facts had already been allowed on the same basis and that course had been left undisturbed by the Supreme Court, the Court ordered release subject to payment of the enhanced duty quantified by Customs, furnishing of a bank guarantee, and maintenance of transaction details for any onward sale. The order expressly preserved Customs' to proceed with adjudication independently and to decide the matter in accordance with law.
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