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 petition challenging the allocation of the Tariff Rate Quota (TRQ) under the India-UAE CEPA for FY 2025-26. The court held that the allocation process, governed by Notification Nos. 22/2022 and 20/2023-Customs and executed by the DGFT, constitutes a policy decision within the respondent government's prerogative. The DGFT, upon receiving numerous applications exceeding available quota, applied eligibility criteria including minimum average turnover thresholds, in accordance with established policy parameters. The HC found no grounds to interfere under Article 226, as the allocation involved discretionary policy considerations and regulatory compliance. Consequently, the petitioner's claim was rejected, and the application for TRQ was to be reconsidered afresh only within the prescribed policy framework, affirming the respondent's authority and procedure in quota allotment.
The HC dismissed the petition challenging the allocation of the Tariff Rate Quota (TRQ) under the India-UAE CEPA for FY 2025-26. The court held that the allocation process, governed by Notification Nos. 22/2022 and 20/2023-Customs and executed by the DGFT, constitutes a policy decision within the respondent government's prerogative. The DGFT, upon receiving numerous applications exceeding available quota, applied eligibility criteria including minimum average turnover thresholds, in accordance with established policy parameters. The HC found no grounds to interfere under Article 226, as the allocation involved discretionary policy considerations and regulatory compliance. Consequently, the petitioner's claim was rejected, and the application for TRQ was to be reconsidered afresh only within the prescribed policy framework, affirming the respondent's authority and procedure in quota allotment.
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