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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The High Court declined to exercise extraordinary writ jurisdiction to quash a show cause notice where parallel proceedings against multiple accused were ongoing, reasoning that premature interference could impede inquiries; the writ petition was dismissed without merit adjudication and no quashing was granted. The court did not resolve the petitioner's limitation/time-bar plea but directed the adjudicating authority to consider the petitioner's explanation and relied precedents (including the cited apex decision) while conducting further proceedings, leaving the substantive limitation question open for decision by the respondents-authority in accordance with law.
The High Court declined to exercise extraordinary writ jurisdiction to quash a show cause notice where parallel proceedings against multiple accused were ongoing, reasoning that premature interference could impede inquiries; the writ petition was dismissed without merit adjudication and no quashing was granted. The court did not resolve the petitioner's limitation/time-bar plea but directed the adjudicating authority to consider the petitioner's explanation and relied precedents (including the cited apex decision) while conducting further proceedings, leaving the substantive limitation question open for decision by the respondents-authority in accordance with law.
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