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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Stay of demand - assessee in default - Mere filing of appeal does not suo-moto stay the recovery proceedings - AO is empowered to exercise his discretion, subject to conditions as he may think fit to impose in the circumstances of case, even though the time for payment has expired, as long as such appeal remains disposed of - HC
Stay of demand - assessee in default - Mere filing of appeal does not suo-moto stay the recovery proceedings - AO is empowered to exercise his discretion, subject to conditions as he may think fit to impose in the circumstances of case, even though the time for payment has expired, as long as such appeal remains disposed of - HC
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