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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HC dismissed the writ petition filed by a foreign citizen of Indian origin challenging the legality of an immovable property acquisition and RBI's acceptance of Form IPI-7. It held the petition non-maintainable as the Division Bench, in prior RFAs between the same parties, had already adjudicated that the impugned transaction complied with FERA and RBI's Notification, including remittance through NRO/NRE/FCNR accounts and RBI's conditional acceptance of repatriation. The HC refused to reopen issues finally decided in the appeals and further noted that the petitioner was seeking relief under the repealed FERA beyond the limitation in FEMA s.49(3). The writ petition was dismissed, liberty being reserved to pursue other appropriate remedies.
HC dismissed the writ petition filed by a foreign citizen of Indian origin challenging the legality of an immovable property acquisition and RBI's acceptance of Form IPI-7. It held the petition non-maintainable as the Division Bench, in prior RFAs between the same parties, had already adjudicated that the impugned transaction complied with FERA and RBI's Notification, including remittance through NRO/NRE/FCNR accounts and RBI's conditional acceptance of repatriation. The HC refused to reopen issues finally decided in the appeals and further noted that the petitioner was seeking relief under the repealed FERA beyond the limitation in FEMA s.49(3). The writ petition was dismissed, liberty being reserved to pursue other appropriate remedies.
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