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 - the petitioner paid the amount on the last date by debiting the amount electronically from his bank account. However, after the amount was debited from the petitioner's bank account, it was re-credited back due to technical glitches. - There is no justification in not accepting the declaration of the petitioner under the scheme or in not accepting the payment by the petitioner belatedly. - HC
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - SVLDRS - the petitioner paid the amount on the last date by debiting the amount electronically from his bank account. However, after the amount was debited from the petitioner's bank account, it was re-credited back due to technical glitches. - There is no justification in not accepting the declaration of the petitioner under the scheme or in not accepting the payment by the petitioner belatedly. - HC
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