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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Prosecution proceedings for Non-disclosure of contribution in the Profit and loss Account - political contribution/donation to the tune of Rs. 10.00 lakhs each in two occasion to a particular party during a financial year 2016-17 - It cannot be said that there is a criminal intention for not specifically mentioning the name of the political party as political contribution. When there is no specific column in the format of the disclosure of the financial status of the company, the question of allegation for non disclosure of political donation does not arise. - HC
Prosecution proceedings for Non-disclosure of contribution in the Profit and loss Account - political contribution/donation to the tune of Rs. 10.00 lakhs each in two occasion to a particular party during a financial year 2016-17 - It cannot be said that there is a criminal intention for not specifically mentioning the name of the political party as political contribution. When there is no specific column in the format of the disclosure of the financial status of the company, the question of allegation for non disclosure of political donation does not arise. - HC
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