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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Writ jurisdiction was invoked to challenge detention/seizure proceedings on the plea that the goods were released on lesser security under s.129(1)(a) of the U.P. GST Act, that invoices could not be doubted without any survey, and that the show cause notice having been issued in the driver's name could not prejudice the supplier. The Court held that reliance on alleged "consistency" with other writ orders is misplaced because writ relief is discretionary and fact-sensitive, and even minor factual differences justify different outcomes. As the petitioner had an efficacious statutory appeal and the contentions involved disputed factual issues (including service and non-response to the notice), writ interference was refused and the petition was dismissed - HC
Writ jurisdiction was invoked to challenge detention/seizure proceedings on the plea that the goods were released on lesser security under s.129(1)(a) of the U.P. GST Act, that invoices could not be doubted without any survey, and that the show cause notice having been issued in the driver's name could not prejudice the supplier. The Court held that reliance on alleged "consistency" with other writ orders is misplaced because writ relief is discretionary and fact-sensitive, and even minor factual differences justify different outcomes. As the petitioner had an efficacious statutory appeal and the contentions involved disputed factual issues (including service and non-response to the notice), writ interference was refused and the petition was dismissed - HC
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