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 interference in departmental disciplinary proceedings is confined to exceptional cases; the court found a prima facie defect in attribution of alleged overwriting because the charged assessment orders were passed when the petitioner held a different post, undermining the foundation of the charges. Rather than permanently quashing the inquiry, the court limited relief by directing the inquiry to proceed expeditiously and fairly under judicial supervision, imposing a timetable for completion and allowing the petitioner to continue in service while cooperating with the process.
Writ interference in departmental disciplinary proceedings is confined to exceptional cases; the court found a prima facie defect in attribution of alleged overwriting because the charged assessment orders were passed when the petitioner held a different post, undermining the foundation of the charges. Rather than permanently quashing the inquiry, the court limited relief by directing the inquiry to proceed expeditiously and fairly under judicial supervision, imposing a timetable for completion and allowing the petitioner to continue in service while cooperating with the process.
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