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 for Tax Relief under the provisions of Sabka Vikas [Legacy Dispute Resolution) Scheme, 2019 - mistake apparent on record or sufficient reasons for review - It is undeniable that the attention of the Court is not drawn to material statutory provisions and the material circumstances. Thus, obvious sufficient reasons are established for review as envisaged under Order XLVII Rule 1 of CPC without calling for much probing. Therefore, this Court, answering the question for consideration in favour of the petitioner, opines that the order must be reviewed - Order recalled - HC
Rejection of declaration for Tax Relief under the provisions of Sabka Vikas [Legacy Dispute Resolution) Scheme, 2019 - mistake apparent on record or sufficient reasons for review - It is undeniable that the attention of the Court is not drawn to material statutory provisions and the material circumstances. Thus, obvious sufficient reasons are established for review as envisaged under Order XLVII Rule 1 of CPC without calling for much probing. Therefore, this Court, answering the question for consideration in favour of the petitioner, opines that the order must be reviewed - Order recalled - HC
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