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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Sabka Vishwas (Legacy) Dispute Resolution Scheme, 2019 - SVLDRS - delay in payment due to adjustment of amounts paid by the insurance company against the payment under the scheme - The stand of the Respondents in this regard is clearly hyper technical and arbitrary. The further stand of the Respondents that the last date for payment has expired on 30.09.2020 is also not acceptable. The delay in receiving payment is on account of the refusal of the Respondent No.3 to adjust the compensation amount payable by the 6th Respondent against the crystallised due under the scheme. The 6th Respondent had also issued the discharge voucher on 29.9.2020 and as such it cannot be said that the offer to pay had not been made before the last date. - HC
Sabka Vishwas (Legacy) Dispute Resolution Scheme, 2019 - SVLDRS - delay in payment due to adjustment of amounts paid by the insurance company against the payment under the scheme - The stand of the Respondents in this regard is clearly hyper technical and arbitrary. The further stand of the Respondents that the last date for payment has expired on 30.09.2020 is also not acceptable. The delay in receiving payment is on account of the refusal of the Respondent No.3 to adjust the compensation amount payable by the 6th Respondent against the crystallised due under the scheme. The 6th Respondent had also issued the discharge voucher on 29.9.2020 and as such it cannot be said that the offer to pay had not been made before the last date. - HC
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