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 stayed the operation of impugned proceedings challenging permissions granted under Section 65 of the Customs Act, finding prima facie merit in the petitioner's case regarding the applicability of Section 65 and prohibitions under MOOWR Regulations. The interim relief allows the petitioner to install and operate equipment for power generation and supply for home consumption, pending resolution of related matters before the Supreme Court in SLP(C) No. 20274-20281 of 2024. The Court directed that 15% of payments received under the PPAs dated 02.02.2022 and 07.07.2022 be deducted and retained in a fixed deposit by State Bank of India, Jubilee Hills Branch, Hyderabad until further orders, thus balancing the petitioner's rights with the Department's interests.
The HC stayed the operation of impugned proceedings challenging permissions granted under Section 65 of the Customs Act, finding prima facie merit in the petitioner's case regarding the applicability of Section 65 and prohibitions under MOOWR Regulations. The interim relief allows the petitioner to install and operate equipment for power generation and supply for home consumption, pending resolution of related matters before the Supreme Court in SLP(C) No. 20274-20281 of 2024. The Court directed that 15% of payments received under the PPAs dated 02.02.2022 and 07.07.2022 be deducted and retained in a fixed deposit by State Bank of India, Jubilee Hills Branch, Hyderabad until further orders, thus balancing the petitioner's rights with the Department's interests.
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