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 petition for want of maintainability, holding that the Petitioner possessed an alternate and efficacious remedy and therefore had not justified bypassing statutory appellate processes. The court reiterated that alleged violations of natural justice may excuse exhaustion of remedies only where the breach is obvious on the face of the record; where such allegations require factual appraisal, the appropriate appellate forum, not the writ jurisdiction, must adjudicate them. Applying established precedent, the HC concluded there was no entitlement to extraordinary relief and declined to entertain the petition, which was accordingly dismissed.
The HC dismissed the writ petition for want of maintainability, holding that the Petitioner possessed an alternate and efficacious remedy and therefore had not justified bypassing statutory appellate processes. The court reiterated that alleged violations of natural justice may excuse exhaustion of remedies only where the breach is obvious on the face of the record; where such allegations require factual appraisal, the appropriate appellate forum, not the writ jurisdiction, must adjudicate them. Applying established precedent, the HC concluded there was no entitlement to extraordinary relief and declined to entertain the petition, which was accordingly dismissed.
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