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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Writ jurisdiction under Articles 226 and 227 was held unavailable to seek early listing of a transfer application or restraint on a tribunal's adjudicating bench while proceedings were pending before the competent tribunal. The text states that constitution of a special Bench and vacation listing fell within the exclusive prerogative of the Tribunal President, and that such relief should be pursued before the tribunal itself. It also notes the availability of an alternative statutory remedy, the belated filing of the transfer application after participation in insolvency proceedings, and that pursuing substantially identical reliefs in multiple forums amounted to forum shopping and abuse of process, leading to dismissal with costs.
Writ jurisdiction under Articles 226 and 227 was held unavailable to seek early listing of a transfer application or restraint on a tribunal's adjudicating bench while proceedings were pending before the competent tribunal. The text states that constitution of a special Bench and vacation listing fell within the exclusive prerogative of the Tribunal President, and that such relief should be pursued before the tribunal itself. It also notes the availability of an alternative statutory remedy, the belated filing of the transfer application after participation in insolvency proceedings, and that pursuing substantially identical reliefs in multiple forums amounted to forum shopping and abuse of process, leading to dismissal with costs.
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