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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Judicial restraint applied where a writ petition sought mandamus to enforce statutory duties against alleged tax evasion based on disputed unaccounted cash transactions and supporting material. The Court held that the Single Judge was in declining to enter the merits and in refusing mandamus at that stage, because no illegality, irregularity, or jurisdictional error was shown in that approach. The writ jurisdiction was therefore not interfered with in appeal, and the writ appeal was dismissed as devoid of merit.
Judicial restraint applied where a writ petition sought mandamus to enforce statutory duties against alleged tax evasion based on disputed unaccounted cash transactions and supporting material. The Court held that the Single Judge was in declining to enter the merits and in refusing mandamus at that stage, because no illegality, irregularity, or jurisdictional error was shown in that approach. The writ jurisdiction was therefore not interfered with in appeal, and the writ appeal was dismissed as devoid of merit.
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