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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Reverse charge of Goods and Services Tax (GST) on recovery agent services - Constitutional validity of Collection of Tax / GST under RCM - The Delhi High Court's judgment underscores the legislative discretion in tax matters, reaffirming the validity of the reverse charge mechanism within the GST framework. It illustrates the balance between legislative intent and constitutional mandates, ensuring that tax laws are applied equitably without disrupting the underlying objectives of the GST regime. By dismissing the petition, the Court reaffirmed that the mechanism of tax collection and the conditional provision of input tax credit do not, in themselves, constitute discrimination or arbitrariness under the Constitution.
Reverse charge of Goods and Services Tax (GST) on recovery agent services - Constitutional validity of Collection of Tax / GST under RCM - The Delhi High Court's judgment underscores the legislative discretion in tax matters, reaffirming the validity of the reverse charge mechanism within the GST framework. It illustrates the balance between legislative intent and constitutional mandates, ensuring that tax laws are applied equitably without disrupting the underlying objectives of the GST regime. By dismissing the petition, the Court reaffirmed that the mechanism of tax collection and the conditional provision of input tax credit do not, in themselves, constitute discrimination or arbitrariness under the Constitution.
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