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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC dismissed the writ petition as not maintainable on the ground of availability of an alternative efficacious statutory remedy under Section 85 of the Finance Act, 1994. The petitioner's challenge to the Demand-cum-Show Cause Notice and Order-in-Original as time-barred, and to the invocation of the extended limitation under Section 73, was held to be a matter within the jurisdiction of the appellate authority, not warranting HC interference under Article 226. The Court declined to adjudicate on "suppression of facts" or validity of extended limitation. Liberty was granted to the petitioner to file an appeal, with a direction that time spent in the writ proceedings be excluded for limitation purposes.
HC dismissed the writ petition as not maintainable on the ground of availability of an alternative efficacious statutory remedy under Section 85 of the Finance Act, 1994. The petitioner's challenge to the Demand-cum-Show Cause Notice and Order-in-Original as time-barred, and to the invocation of the extended limitation under Section 73, was held to be a matter within the jurisdiction of the appellate authority, not warranting HC interference under Article 226. The Court declined to adjudicate on "suppression of facts" or validity of extended limitation. Liberty was granted to the petitioner to file an appeal, with a direction that time spent in the writ proceedings be excluded for limitation purposes.
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