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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It is settled principle of interpretation of fiscal law that taxing statute should be construed strictly. When the provision is free from doubt or ambiguity, there is no need to draw any analogy. If the subject comes within the letter of the provision, then it must be taxed however great the hardship appears to be to the mind of the court. - AT
It is settled principle of interpretation of fiscal law that taxing statute should be construed strictly. When the provision is free from doubt or ambiguity, there is no need to draw any analogy. If the subject comes within the letter of the provision, then it must be taxed however great the hardship appears to be to the mind of the court. - AT
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