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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TP adjustments - Period of limitation for proceedings before the DRP - As to acquiescence of the petitioner, reject the submission of the respondents for the reason that once an order is established to be beyond limitation, mere co-operation of the party in the proceedings would not extend the same. In fact, even as on 29.01.2020 when the petitioner had written to the DRP, limitation had long expired and thus there is no merit in this submission of the respondents. - HC
TP adjustments - Period of limitation for proceedings before the DRP - As to acquiescence of the petitioner, reject the submission of the respondents for the reason that once an order is established to be beyond limitation, mere co-operation of the party in the proceedings would not extend the same. In fact, even as on 29.01.2020 when the petitioner had written to the DRP, limitation had long expired and thus there is no merit in this submission of the respondents. - HC
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