SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
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Writ jurisdiction remains available despite an alternate statutory remedy where the challenge concerns seizure power, jurisdictional facts or deficient administrative decision-making, although factual merits remain for the statutory authority. Foreign-exchange seizure powers cannot retrospectively reach completed pre-commencement transactions, but may extend to actual payments made after commencement under a continuing arrangement. Connected financial transactions may be examined as a whole to establish a preliminary reason to believe, and recorded reasons cannot later be replaced by new grounds. Regulatory and tax proceedings do not preclude an independent foreign-exchange inquiry. Refusal of an overseas-investment no-objection certificate requires disclosed, rational reasons linked to the investigation; the unreasoned refusal required fresh consideration.
Writ jurisdiction remains available despite an alternate statutory remedy where the challenge concerns seizure power, jurisdictional facts or deficient administrative decision-making, although factual merits remain for the statutory authority. Foreign-exchange seizure powers cannot retrospectively reach completed pre-commencement transactions, but may extend to actual payments made after commencement under a continuing arrangement. Connected financial transactions may be examined as a whole to establish a preliminary reason to believe, and recorded reasons cannot later be replaced by new grounds. Regulatory and tax proceedings do not preclude an independent foreign-exchange inquiry. Refusal of an overseas-investment no-objection certificate requires disclosed, rational reasons linked to the investigation; the unreasoned refusal required fresh consideration.
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