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...
The petition was dismissed by the High Court as no case was made out to depart from the usual rule of exhaustion of alternative remedies. The key reasons were: 1) An alternative remedy of appeal was available against the impugned order, although the petitioner contended violation of principles of natural justice. 2) The petition was filed almost a year after the impugned orders, much beyond the statutory limitation period for appeal, without any explanation for the delay. While there is no limitation for filing a petition under Article 226, such petitions must be instituted within a reasonable period, and any delay is required to be explained. Since the petitioner failed to provide a justification for the inordinate delay, the High Court dismissed the petition.
The petition was dismissed by the High Court as no case was made out to depart from the usual rule of exhaustion of alternative remedies. The key reasons were: 1) An alternative remedy of appeal was available against the impugned order, although the petitioner contended violation of principles of natural justice. 2) The petition was filed almost a year after the impugned orders, much beyond the statutory limitation period for appeal, without any explanation for the delay. While there is no limitation for filing a petition under Article 226, such petitions must be instituted within a reasonable period, and any delay is required to be explained. Since the petitioner failed to provide a justification for the inordinate delay, the High Court dismissed the petition.
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