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 HC quashed the mid-term revision of Bullion TRQ allocations under the India-UAE CEPA for FY 2024-25 by the DGFT due to violation of natural justice principles. The petitioner was not granted a hearing opportunity or sufficient prior notice. Relying on its previous decision in KAKA GOLD LLP v. DGFT, the HC directed the DGFT to re-examine the issues raised by the petitioners after providing them an opportunity to be heard, maintain current allocations during the review process, and clearly communicate the criteria for TRQ revisions. Fresh orders were to be issued within three weeks after the petitioners filed a review application within one week.
The HC quashed the mid-term revision of Bullion TRQ allocations under the India-UAE CEPA for FY 2024-25 by the DGFT due to violation of natural justice principles. The petitioner was not granted a hearing opportunity or sufficient prior notice. Relying on its previous decision in KAKA GOLD LLP v. DGFT, the HC directed the DGFT to re-examine the issues raised by the petitioners after providing them an opportunity to be heard, maintain current allocations during the review process, and clearly communicate the criteria for TRQ revisions. Fresh orders were to be issued within three weeks after the petitioners filed a review application within one week.
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