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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Stay of demand - payment of 20% of the outstanding demand - ITAT rejecting its application for stay on the recovery of demand during the pendency of appeal - The Delhi High Court dismissed the petition challenging the ITAT's order on the recovery of tax demand from a national political party. The judgment underlines the importance of compliance with statutory requirements, especially timely filing of tax returns and adherence to conditions for receiving donations, to qualify for exemptions. It also highlights the significance of the taxpayer's conduct in seeking relief from tax demands, concluding that the petitioner's lackadaisical approach and failure to engage with the tax authorities in a timely manner undermined its position.
Stay of demand - payment of 20% of the outstanding demand - ITAT rejecting its application for stay on the recovery of demand during the pendency of appeal - The Delhi High Court dismissed the petition challenging the ITAT's order on the recovery of tax demand from a national political party. The judgment underlines the importance of compliance with statutory requirements, especially timely filing of tax returns and adherence to conditions for receiving donations, to qualify for exemptions. It also highlights the significance of the taxpayer's conduct in seeking relief from tax demands, concluding that the petitioner's lackadaisical approach and failure to engage with the tax authorities in a timely manner undermined its position.
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