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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SVLDRS - re-determination of the 'amount payable' under the scheme - The deposit towards duty paid during investigation and during pendency of appeal proceedings in the form of pre-deposit in the present case may be appropriated and deducted from the tax dues after grant of relief under section 124(1)(a) of the said. - However, Respondents directed to refund ₹ 45,60,438/- to the Petitioner out of the amount of ₹ 55,56,045/- paid by the Petitioner as per Order dated 30.06.2020 of this Hon'ble Court. - HC
SVLDRS - re-determination of the 'amount payable' under the scheme - The deposit towards duty paid during investigation and during pendency of appeal proceedings in the form of pre-deposit in the present case may be appropriated and deducted from the tax dues after grant of relief under section 124(1)(a) of the said. - However, Respondents directed to refund ₹ 45,60,438/- to the Petitioner out of the amount of ₹ 55,56,045/- paid by the Petitioner as per Order dated 30.06.2020 of this Hon'ble Court. - HC
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