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, applying the Supreme Court's ruling in Canon-II, held that DRI officers (including the Additional Director General) are not the proper officers empowered under Section 28(4) to initiate recovery/issue show-cause notices; consequently the impugned recovery proceedings were without jurisdiction. The HC overruled the effect of Mangali Impex as no longer good law, allowed the appellant's challenge, set aside the jurisdictional initiation, and restored the appeal before CESTAT to its original position for adjudication. The appeal is allowed and the contested proceedings are quashed to the extent founded on exercise of Section 28(4) powers by DRI officers.
The HC, applying the Supreme Court's ruling in Canon-II, held that DRI officers (including the Additional Director General) are not the proper officers empowered under Section 28(4) to initiate recovery/issue show-cause notices; consequently the impugned recovery proceedings were without jurisdiction. The HC overruled the effect of Mangali Impex as no longer good law, allowed the appellant's challenge, set aside the jurisdictional initiation, and restored the appeal before CESTAT to its original position for adjudication. The appeal is allowed and the contested proceedings are quashed to the extent founded on exercise of Section 28(4) powers by DRI officers.
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