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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Timelines under Regulation 17 of the Customs Brokers Licensing Regulations, 2018 were treated as mandatory, and failure to comply vitiated the proceedings. The High Court found that, on the undisputed dates, the inquiry report had been submitted beyond the 90-day period prescribed under Regulation 17(5). Rejecting the argument that the timeline was merely directory because no express consequence was stated, the Court held that non-adherence to the statutory period was sufficient to invalidate the action. The show cause notice and inquiry report were therefore quashed, and the writ petition was allowed.
Timelines under Regulation 17 of the Customs Brokers Licensing Regulations, 2018 were treated as mandatory, and failure to comply vitiated the proceedings. The High Court found that, on the undisputed dates, the inquiry report had been submitted beyond the 90-day period prescribed under Regulation 17(5). Rejecting the argument that the timeline was merely directory because no express consequence was stated, the Court held that non-adherence to the statutory period was sufficient to invalidate the action. The show cause notice and inquiry report were therefore quashed, and the writ petition was allowed.
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