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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Challenge to the warrant of authorization raised identical legal contention already admitted before a tribunal and pending as an appeal in another High Court; applying the abstention principle for parallel proceedings, the High Court declined to entertain a fresh writ on the same controversy and dismissed the petition while granting liberty to seek framing of an additional substantial question of law in the pending appeal. The outcome turns on duplicative litigation and preservation of appellate remedy rather than re examination of the authorization on merits.
Challenge to the warrant of authorization raised identical legal contention already admitted before a tribunal and pending as an appeal in another High Court; applying the abstention principle for parallel proceedings, the High Court declined to entertain a fresh writ on the same controversy and dismissed the petition while granting liberty to seek framing of an additional substantial question of law in the pending appeal. The outcome turns on duplicative litigation and preservation of appellate remedy rather than re examination of the authorization on merits.
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