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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Amendment of pleadings and joinder of parties are permitted as a means to secure the right to adjudication on merits and to give effect to principles of natural justice where non-joinder caused dismissal; the tribunal's remedial power to allow rectification of the cause title is exercised in the interest of justice. The impugned dismissal is modified to permit the appellant to implead the necessary party, M/s. Al-Sami Food Exports Pvt Ltd, within two weeks, and respondents retain the right to file their counter after such amendment, preserving equitable balance and opportunity to decide the lis on merits.
Amendment of pleadings and joinder of parties are permitted as a means to secure the right to adjudication on merits and to give effect to principles of natural justice where non-joinder caused dismissal; the tribunal's remedial power to allow rectification of the cause title is exercised in the interest of justice. The impugned dismissal is modified to permit the appellant to implead the necessary party, M/s. Al-Sami Food Exports Pvt Ltd, within two weeks, and respondents retain the right to file their counter after such amendment, preserving equitable balance and opportunity to decide the lis on merits.
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