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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Seeking condonation of delay of 470 days in filing the review petition - The issue was decided against the revenue [2018 (10) TMI 709 - DELHI HIGH COURT] - It is well-settled that each day of the delay is required to be explained. In the present case, the delay is substantial and no particulars to explain the delay have been provided. - The application is dismissed. - HC
Seeking condonation of delay of 470 days in filing the review petition - The issue was decided against the revenue [2018 (10) TMI 709 - DELHI HIGH COURT] - It is well-settled that each day of the delay is required to be explained. In the present case, the delay is substantial and no particulars to explain the delay have been provided. - The application is dismissed. - HC
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