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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PIL - Seeking for a direction against respondents No. 1 to 10 therein to forthwith constitute a Multi- Disciplinary Investigation Team to investigate and prosecute respondent No.11 - It is important to note that petitioner's complaint dated March 14, 2017 upon which petitioner has relied is common in the PIL filed before the Delhi High Court and this writ petition - thus, there remains no doubt that petitioner is indulging in forum shopping on the very same cause of action. As held in Udyami2, this amounts to criminal contempt as the core issue in all these writ petitions is one and the same. - This writ petition is not only devoid of merits, but an absolute abuse of process of law. - HC
PIL - Seeking for a direction against respondents No. 1 to 10 therein to forthwith constitute a Multi- Disciplinary Investigation Team to investigate and prosecute respondent No.11 - It is important to note that petitioner's complaint dated March 14, 2017 upon which petitioner has relied is common in the PIL filed before the Delhi High Court and this writ petition - thus, there remains no doubt that petitioner is indulging in forum shopping on the very same cause of action. As held in Udyami2, this amounts to criminal contempt as the core issue in all these writ petitions is one and the same. - This writ petition is not only devoid of merits, but an absolute abuse of process of law. - HC
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