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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SC dismissed the special leave petition challenging a provisional attachment order under the PMLA, upholding the High Court's refusal to entertain a writ petition under Article 226 where a specific statutory appellate remedy is available. The Court held that the High Court's exercise of discretion to decline writ relief was neither arbitrary nor perverse. Accordingly, the petitioner's challenge is dismissed, with the petitioner granted liberty to pursue the prescribed appellate remedy under the statute. The decision affirms that where a statutory remedy exists, extraordinary constitutional writ jurisdiction will generally be declined, and parties must resort to the designated appellate forum for adjudication of attachment and related relief.
SC dismissed the special leave petition challenging a provisional attachment order under the PMLA, upholding the High Court's refusal to entertain a writ petition under Article 226 where a specific statutory appellate remedy is available. The Court held that the High Court's exercise of discretion to decline writ relief was neither arbitrary nor perverse. Accordingly, the petitioner's challenge is dismissed, with the petitioner granted liberty to pursue the prescribed appellate remedy under the statute. The decision affirms that where a statutory remedy exists, extraordinary constitutional writ jurisdiction will generally be declined, and parties must resort to the designated appellate forum for adjudication of attachment and related relief.
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