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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Refund of excess TDS deducted u/s 195 - Unjust Enrichment of the Government - whether the respondents are authorised by law to withhold the excess TDS paid by the petitioner? - Latin maxim “jure naturae aequum est, neminem cum alterius detrimento, et injuria fieri locupletioremit” - The High Court, after considering constitutional provisions, legal principles, and precedents, held that the excess TDS deposited by the company should be refunded. It emphasized that tax collection should only be done in accordance with the law.
Refund of excess TDS deducted u/s 195 - Unjust Enrichment of the Government - whether the respondents are authorised by law to withhold the excess TDS paid by the petitioner? - Latin maxim “jure naturae aequum est, neminem cum alterius detrimento, et injuria fieri locupletioremit” - The High Court, after considering constitutional provisions, legal principles, and precedents, held that the excess TDS deposited by the company should be refunded. It emphasized that tax collection should only be done in accordance with the law.
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