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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Refusal of MESI benefits violated Article 14's doctrine of equality. Conversion of Shipping Bills from one scheme to another was allowed by the learned Single Judge. The contention that the digitally handled scheme precludes human intervention and error rectification was deemed too far-fetched. In human institutions, errors occur and need rectification in the absence of contrary law. Innocuous errors disadvantaging citizens cannot be justified in a Welfare State. No rule prescribes a limitation period prohibiting condonation of delay. The Appeal lacking merits was dismissed.
Refusal of MESI benefits violated Article 14's doctrine of equality. Conversion of Shipping Bills from one scheme to another was allowed by the learned Single Judge. The contention that the digitally handled scheme precludes human intervention and error rectification was deemed too far-fetched. In human institutions, errors occur and need rectification in the absence of contrary law. Innocuous errors disadvantaging citizens cannot be justified in a Welfare State. No rule prescribes a limitation period prohibiting condonation of delay. The Appeal lacking merits was dismissed.
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