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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The High Court allowed the petition, declaring that the petitioner is entitled to authorization to import an additional 8,000 Metric Tonnes of Maize Corn/Pop Corn. The Court held that the respondents' refusal to grant the balance authorization of 8,000 Metric Tonnes to the petitioner for importing Maize Corn/Pop Corn was arbitrary and violative of Article 19(1)(g) of the Constitution of India. The Court directed the respondents to issue the authorization for the remaining 8,000 Metric Tonnes expeditiously, within four weeks from the date of the order. The Court found that the restrictions imposed by granting authorization for only 2,000 Metric Tonnes were without statutory backing u/ss 3 and 9A of the Act of 1992 and the Foreign Trade Policy 2023. The exercise of discretion by the respondents in limiting the authorization was held to be unfair and contrary to the principles of due process and legitimate expectation.
The High Court allowed the petition, declaring that the petitioner is entitled to authorization to import an additional 8,000 Metric Tonnes of Maize Corn/Pop Corn. The Court held that the respondents' refusal to grant the balance authorization of 8,000 Metric Tonnes to the petitioner for importing Maize Corn/Pop Corn was arbitrary and violative of Article 19(1)(g) of the Constitution of India. The Court directed the respondents to issue the authorization for the remaining 8,000 Metric Tonnes expeditiously, within four weeks from the date of the order. The Court found that the restrictions imposed by granting authorization for only 2,000 Metric Tonnes were without statutory backing u/ss 3 and 9A of the Act of 1992 and the Foreign Trade Policy 2023. The exercise of discretion by the respondents in limiting the authorization was held to be unfair and contrary to the principles of due process and legitimate expectation.
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