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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A High Court addressed a suit for specific performance and damages, considering whether Section 31 of the Foreign Exchange Regulation Act barred the suit and whether prior findings created res judicata. The court confined its adverse decision on an additional issue framed on January 4, 2023 to that narrow issue, holding that this determination will not prejudice the parties on the four original issues framed on December 14, 1992. Questions on legality, validity, sufficiency and enforceability of the January 2, 1989 agreement, including its effect under the Income Tax Act and other FERA aspects, remain open for full adjudication at trial.
A High Court addressed a suit for specific performance and damages, considering whether Section 31 of the Foreign Exchange Regulation Act barred the suit and whether prior findings created res judicata. The court confined its adverse decision on an additional issue framed on January 4, 2023 to that narrow issue, holding that this determination will not prejudice the parties on the four original issues framed on December 14, 1992. Questions on legality, validity, sufficiency and enforceability of the January 2, 1989 agreement, including its effect under the Income Tax Act and other FERA aspects, remain open for full adjudication at trial.
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