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 applied the principle of Constructive Res Judicata to dismiss the writ petition challenging Clause 3.3 of the Guidelines for Grant of Reward to Informers and Government Servants, 2015. The court held that since the petitioner failed to raise the constitutional challenge in the earlier round of litigation, they are precluded from doing so now. The doctrine aims to prevent multiplicity of litigation and ensure parties present their entire case in a single proceeding. Consequently, the writ petition was deemed not maintainable and summarily dismissed, upholding the principle of finality in legal proceedings.
The HC applied the principle of Constructive Res Judicata to dismiss the writ petition challenging Clause 3.3 of the Guidelines for Grant of Reward to Informers and Government Servants, 2015. The court held that since the petitioner failed to raise the constitutional challenge in the earlier round of litigation, they are precluded from doing so now. The doctrine aims to prevent multiplicity of litigation and ensure parties present their entire case in a single proceeding. Consequently, the writ petition was deemed not maintainable and summarily dismissed, upholding the principle of finality in legal proceedings.
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