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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Rejection of declaration under Sabka Vishwas [Legacy Dispute Resolution] Scheme, 2019 - SVLDRS - If there was quantification in terms of the Final Reminder as now asserted by the petitioner, in Form in SVLDRS-1 the petitioner should have mentioned in the relevant column the amount indicated in the Final Reminder dated 15.11.2018. The fact that the petitioner mentions the Tax liability/ Demand in Form SVLDRS-1, an amount which is quantified in terms of the Show Cause Notice dated 9.12.2019, shows that even according to the petitioner there was no quantification as of the prescribed date viz., 30.06.2019. - Petition dismissed - HC
Rejection of declaration under Sabka Vishwas [Legacy Dispute Resolution] Scheme, 2019 - SVLDRS - If there was quantification in terms of the Final Reminder as now asserted by the petitioner, in Form in SVLDRS-1 the petitioner should have mentioned in the relevant column the amount indicated in the Final Reminder dated 15.11.2018. The fact that the petitioner mentions the Tax liability/ Demand in Form SVLDRS-1, an amount which is quantified in terms of the Show Cause Notice dated 9.12.2019, shows that even according to the petitioner there was no quantification as of the prescribed date viz., 30.06.2019. - Petition dismissed - HC
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