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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HC upheld the validity of quantitative restrictions on LAM Coke imports imposed through notification dated 26.12.2024. The Court determined that transitional provisions under Clause 1.05 of the Foreign Trade Policy 2023 do not apply to safeguard measures implemented under Section 9A of the FTDR Act and Safeguard Rules, 2012. The notification followed proper investigation procedures with stakeholder participation and final findings by DGTR. The Court emphasized that safeguard measures designed to protect domestic industries from import surges operate independently and are not subject to transitional arrangements. Petitioners' applications for operational listing of ICLCs were deemed moot as the restrictions took effect from the notification date without requiring further transitional arrangements.
HC upheld the validity of quantitative restrictions on LAM Coke imports imposed through notification dated 26.12.2024. The Court determined that transitional provisions under Clause 1.05 of the Foreign Trade Policy 2023 do not apply to safeguard measures implemented under Section 9A of the FTDR Act and Safeguard Rules, 2012. The notification followed proper investigation procedures with stakeholder participation and final findings by DGTR. The Court emphasized that safeguard measures designed to protect domestic industries from import surges operate independently and are not subject to transitional arrangements. Petitioners' applications for operational listing of ICLCs were deemed moot as the restrictions took effect from the notification date without requiring further transitional arrangements.
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