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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Application under Direct Tax Vivad Se Vishwas Act, 2020 (DTVSV Act). - Seeking Adjust/give credit to the amount paid by petitioner under the Income Declaration Scheme, 2016 (“the IDS”) - The Scheme does not provide for Revenue to retain the tax so paid in respect of a declaration which is void and non-est. Article 265 of the Constitution of India provides that no tax shall be levied or collected except by authority of law. - Petitioner is entitled to an adjustment by giving credit to the amount paid under IDS. - HC
Application under Direct Tax Vivad Se Vishwas Act, 2020 (DTVSV Act). - Seeking Adjust/give credit to the amount paid by petitioner under the Income Declaration Scheme, 2016 (“the IDS”) - The Scheme does not provide for Revenue to retain the tax so paid in respect of a declaration which is void and non-est. Article 265 of the Constitution of India provides that no tax shall be levied or collected except by authority of law. - Petitioner is entitled to an adjustment by giving credit to the amount paid under IDS. - HC
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