Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Liability for non-registration turned on allocation of operational roles under the MOU and Guidelines: uploading contracts to the foreign online portal was the foreign authority's distinct obligation, while the domestic authority's duty arose only to verify entries already reflected on that portal; consequently the domestic authority could not be held liable for the foreign authority's failure to upload. Challenges to fixation of the Country Cap and its allocation raised economic policy issues; the court declined to substitute judgment for a plausible policy decision absent manifest arbitrariness, unreasonableness, or mala fides, and found no violation of equality or trade rights.
Liability for non-registration turned on allocation of operational roles under the MOU and Guidelines: uploading contracts to the foreign online portal was the foreign authority's distinct obligation, while the domestic authority's duty arose only to verify entries already reflected on that portal; consequently the domestic authority could not be held liable for the foreign authority's failure to upload. Challenges to fixation of the Country Cap and its allocation raised economic policy issues; the court declined to substitute judgment for a plausible policy decision absent manifest arbitrariness, unreasonableness, or mala fides, and found no violation of equality or trade rights.
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