Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Writ jurisdiction may extend to a private bank when it acts as an Authorised Dealer under the FEMA-RBI framework and its refusal to process foreign exchange transactions is challenged as arbitrary. The article notes that contractual banking dealings do not exclude judicial review where a public law element exists, and that a clean-hands objection based on alleged suppression will not automatically bar a petition if the disputed facts are part of the main controversy. It also explains that the bank could require enhanced due diligence and refuse processing when later material raised sanctions-related concerns, with the writ court declining to reappreciate disputed commercial facts and no interference being made under Article 226.
Writ jurisdiction may extend to a private bank when it acts as an Authorised Dealer under the FEMA-RBI framework and its refusal to process foreign exchange transactions is challenged as arbitrary. The article notes that contractual banking dealings do not exclude judicial review where a public law element exists, and that a clean-hands objection based on alleged suppression will not automatically bar a petition if the disputed facts are part of the main controversy. It also explains that the bank could require enhanced due diligence and refuse processing when later material raised sanctions-related concerns, with the writ court declining to reappreciate disputed commercial facts and no interference being made under Article 226.
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