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 upheld that the DGFT notification relied on powers under Sections 3 and 5 of the Foreign Trade (Development & Regulation) Act, 1992 and on paragraphs 1.02 and 2.01 of the FTP, recognising the Central Government's competence to amend the FTP and to regulate imports by prohibition or restriction. Notwithstanding this statutory foundation, the court found that the Petitioner established a strong prima facie case and granted ad-interim relief pendente lite, listing the matter for consideration of interim reliefs on 13 Nov 2025. The classification change and import prohibition remain subject to final adjudication.
The HC upheld that the DGFT notification relied on powers under Sections 3 and 5 of the Foreign Trade (Development & Regulation) Act, 1992 and on paragraphs 1.02 and 2.01 of the FTP, recognising the Central Government's competence to amend the FTP and to regulate imports by prohibition or restriction. Notwithstanding this statutory foundation, the court found that the Petitioner established a strong prima facie case and granted ad-interim relief pendente lite, listing the matter for consideration of interim reliefs on 13 Nov 2025. The classification change and import prohibition remain subject to final adjudication.
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