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 dominant issue was whether part of the cause of action arose within the territorial jurisdiction of the Court to entertain a writ challenging anti-dumping final findings on grounds of violation of natural justice and arbitrariness. Applying the test that only facts having a direct nexus with the lis constitute cause of action, the Court held that alleged adverse business impact or commercial engagements within the State were not integral to establishing the asserted infringement of fair procedure under Article 14, and the challenge would survive even if those averments were removed. Consequently, no part of the cause of action arose within its territory, and the writ was not maintainable; the petition was dismissed without examining merits or alternative remedy. - HC
The dominant issue was whether part of the cause of action arose within the territorial jurisdiction of the Court to entertain a writ challenging anti-dumping final findings on grounds of violation of natural justice and arbitrariness. Applying the test that only facts having a direct nexus with the lis constitute cause of action, the Court held that alleged adverse business impact or commercial engagements within the State were not integral to establishing the asserted infringement of fair procedure under Article 14, and the challenge would survive even if those averments were removed. Consequently, no part of the cause of action arose within its territory, and the writ was not maintainable; the petition was dismissed without examining merits or alternative remedy. - HC
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