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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Territorial writ jurisdiction depends on where the dominant, essential and integral facts of the lis arose, not merely on the location of the respondent authority or the place from which the impugned order was issued. Applying the doctrine of forum conveniens and the principle in Kusum Ingots, the HC found that the petitioner's applications and underlying dispute were routed through the Haryana unit, so the foundational cause of action lay outside Delhi. Delhi was therefore not the appropriate forum, and the writ petition was dismissed with liberty to approach the jurisdictional High Court, leaving all rights and contentions open.
Territorial writ jurisdiction depends on where the dominant, essential and integral facts of the lis arose, not merely on the location of the respondent authority or the place from which the impugned order was issued. Applying the doctrine of forum conveniens and the principle in Kusum Ingots, the HC found that the petitioner's applications and underlying dispute were routed through the Haryana unit, so the foundational cause of action lay outside Delhi. Delhi was therefore not the appropriate forum, and the writ petition was dismissed with liberty to approach the jurisdictional High Court, leaving all rights and contentions open.
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