Restricted silver imports may clear under a valid import authorisation without additional status or exchange-routing requirements unless expressly imp...
Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Judicial review of closure of a disciplinary complaint concerning alleged unauthorised access to and alteration of an income-tax account is confined to examining the legality of the decision-making process. Writ jurisdiction does not permit reappreciation of evidence or substitution of the disciplinary authority's view. The absence of a fiduciary relationship did not itself exclude misconduct, but was material where the prima facie view assumed that the Chartered Accountant was the petitioner's tax consultant, which both denied. The closure rested on lack of cogent evidence of mala fide intent or deliberate facilitation, rather than merely pending criminal proceedings; the writ petition was dismissed.
Judicial review of closure of a disciplinary complaint concerning alleged unauthorised access to and alteration of an income-tax account is confined to examining the legality of the decision-making process. Writ jurisdiction does not permit reappreciation of evidence or substitution of the disciplinary authority's view. The absence of a fiduciary relationship did not itself exclude misconduct, but was material where the prima facie view assumed that the Chartered Accountant was the petitioner's tax consultant, which both denied. The closure rested on lack of cogent evidence of mala fide intent or deliberate facilitation, rather than merely pending criminal proceedings; the writ petition was dismissed.
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TaxTMI 
TaxTMI 
of 4905 
