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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Suppression of facts from the Court - In view of this conduct of petitioner, a sizable amount of precious time of court is being wasted. We deem it proper to observe that suppression of facts cannot be termed as ‘advocacy’. If a litigant discloses all the facts correctly and then able to convince the court, it can be treated as skill of advocacy. The litigation is neither a game of chess nor a hide and seek game but a search for truth and parties must place their cards on the table - it is deemed proper to dismiss this petition with exemplary cost. - HC
Suppression of facts from the Court - In view of this conduct of petitioner, a sizable amount of precious time of court is being wasted. We deem it proper to observe that suppression of facts cannot be termed as ‘advocacy’. If a litigant discloses all the facts correctly and then able to convince the court, it can be treated as skill of advocacy. The litigation is neither a game of chess nor a hide and seek game but a search for truth and parties must place their cards on the table - it is deemed proper to dismiss this petition with exemplary cost. - HC
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