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 accumulated input tax credit - relevant date for the purpose of considering the limitation u/s 54 - The High Court addressed this issue by directing the respondent authority to consider the date of filing of the refund application, whether filed manually or online, as the date of filing the manual refund application. This decision aimed to ensure that the petitioner's refund claims would not be rejected based on the limitation period. Additionally, the petitioner was instructed to file fresh refund applications online within four weeks, with the date of such applications deemed to be the date of manual filing.
Refund of accumulated input tax credit - relevant date for the purpose of considering the limitation u/s 54 - The High Court addressed this issue by directing the respondent authority to consider the date of filing of the refund application, whether filed manually or online, as the date of filing the manual refund application. This decision aimed to ensure that the petitioner's refund claims would not be rejected based on the limitation period. Additionally, the petitioner was instructed to file fresh refund applications online within four weeks, with the date of such applications deemed to be the date of manual filing.
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