Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Prohibiting export of Non-Basmati Rice - Retrospective effect of notification - Violation of principles of natural justice - Legitimate expectation - The High Court observed that the FTP 2023 includes a transitional arrangement clause ensuring that changes in policy do not adversely affect existing commitments through irrevocable commercial letters of credit (ICLC). The Court found that the impugned notification unjustifiably denied this benefit to the petitioners, even though similar provisions were applied in other cases, such as wheat exports. The lack of specific reasons for this denial rendered the notification arbitrary. - The court declared that the impugned notification dated 20.07.2023, insofar as it denies the benefit of the transitional arrangement under para 1.05 of FTP 2023, is bad-in-law.
Prohibiting export of Non-Basmati Rice - Retrospective effect of notification - Violation of principles of natural justice - Legitimate expectation - The High Court observed that the FTP 2023 includes a transitional arrangement clause ensuring that changes in policy do not adversely affect existing commitments through irrevocable commercial letters of credit (ICLC). The Court found that the impugned notification unjustifiably denied this benefit to the petitioners, even though similar provisions were applied in other cases, such as wheat exports. The lack of specific reasons for this denial rendered the notification arbitrary. - The court declared that the impugned notification dated 20.07.2023, insofar as it denies the benefit of the transitional arrangement under para 1.05 of FTP 2023, is bad-in-law.
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