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 dismissed the petition challenging the Merchandise Exports from India Scheme (MEIS) benefit denial. The Policy Review Committee (PRC) rejected the export benefit claim due to delayed foreign exchange remittance beyond the prescribed three-year period. For 6 out of 8 shipping bills, payment was realized within three years, allowing potential late fee benefits, which the petitioner did not pursue. The remaining bills were received beyond the stipulated timeframe, rendering them ineligible. The court found no jurisdictional error or arbitrariness in the PRC's decision and upheld the administrative discretion, concluding that policy relaxation cannot be claimed as a substantive right and is subject to exceptional circumstances.
HC dismissed the petition challenging the Merchandise Exports from India Scheme (MEIS) benefit denial. The Policy Review Committee (PRC) rejected the export benefit claim due to delayed foreign exchange remittance beyond the prescribed three-year period. For 6 out of 8 shipping bills, payment was realized within three years, allowing potential late fee benefits, which the petitioner did not pursue. The remaining bills were received beyond the stipulated timeframe, rendering them ineligible. The court found no jurisdictional error or arbitrariness in the PRC's decision and upheld the administrative discretion, concluding that policy relaxation cannot be claimed as a substantive right and is subject to exceptional circumstances.
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