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 dismissed the writ petitions challenging the rejection of appeals under the EPCG license scheme due to delay in filing relevant documents. The court held that the appeals were barred by limitation under Section 15(1)(b) of the Foreign Trade (Development and Regulation) Act, 1992, as the petitioner failed to file the appeal within the prescribed period after acquiring knowledge of the order. Despite fulfilling export obligations, the petitioner's failure to timely submit the necessary forms rendered the fulfillment unsubstantiated. The court emphasized that the delay of nearly two years in approaching the authorities was fatal and declined to interfere with the respondents' proceedings. Consequently, the petitions were dismissed for lack of merit.
The HC dismissed the writ petitions challenging the rejection of appeals under the EPCG license scheme due to delay in filing relevant documents. The court held that the appeals were barred by limitation under Section 15(1)(b) of the Foreign Trade (Development and Regulation) Act, 1992, as the petitioner failed to file the appeal within the prescribed period after acquiring knowledge of the order. Despite fulfilling export obligations, the petitioner's failure to timely submit the necessary forms rendered the fulfillment unsubstantiated. The court emphasized that the delay of nearly two years in approaching the authorities was fatal and declined to interfere with the respondents' proceedings. Consequently, the petitions were dismissed for lack of merit.
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