Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
The HC found prima facie merit in the petitioner's challenge to the respondent's inaction on revalidation of import licences but declined to grant pre-emptory relief or issue a writ of mandamus directing revalidation. Instead, the HC directed the respondent's PRC to reconsider the petitioner's revalidation requests in light of all relevant facts, including decisions concerning similarly situated importers, and to render a reasoned decision. The PRC was instructed to complete the fresh examination expeditiously and preferably within six weeks. The petition was disposed of accordingly.
The HC found prima facie merit in the petitioner's challenge to the respondent's inaction on revalidation of import licences but declined to grant pre-emptory relief or issue a writ of mandamus directing revalidation. Instead, the HC directed the respondent's PRC to reconsider the petitioner's revalidation requests in light of all relevant facts, including decisions concerning similarly situated importers, and to render a reasoned decision. The PRC was instructed to complete the fresh examination expeditiously and preferably within six weeks. The petition was disposed of accordingly.
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