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 held that the petition alleging breach of natural justice did not disclose a clear-cut violation; absence of material evidence, including any test report, precluded reclassification of goods. The court found the question of blending capacity and machinery to be a disputed question of fact more appropriately resolved by the Appellate Authority through the statutory appellate process. The petitioner was not permitted to bypass the prescribed alternate remedy and was refused leave to deviate from exhaustion of remedies. Consequently, the petition was declined admission and dismissed, leaving the petitioner to pursue available statutory appeals before the appropriate administrative appellate forum.
The HC held that the petition alleging breach of natural justice did not disclose a clear-cut violation; absence of material evidence, including any test report, precluded reclassification of goods. The court found the question of blending capacity and machinery to be a disputed question of fact more appropriately resolved by the Appellate Authority through the statutory appellate process. The petitioner was not permitted to bypass the prescribed alternate remedy and was refused leave to deviate from exhaustion of remedies. Consequently, the petition was declined admission and dismissed, leaving the petitioner to pursue available statutory appeals before the appropriate administrative appellate forum.
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