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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Rejection of appellants’ challenge to Summons, summoning the appellants to appear before the Second respondent - The Court found that the second respondent had jurisdiction as per relevant rules and notifications, and the show cause notice directed the appellants to respond to the competent authority. - Although the summons was issued by the second respondent, the show cause notice directed the appellants to respond to the Commissioner of Central Excise and Service Tax 1, Commissionerate, Bengaluru. - Therefore, the Court concluded that there was no reason to interfere with the learned Single Judge’s order regarding jurisdiction.
Rejection of appellants’ challenge to Summons, summoning the appellants to appear before the Second respondent - The Court found that the second respondent had jurisdiction as per relevant rules and notifications, and the show cause notice directed the appellants to respond to the competent authority. - Although the summons was issued by the second respondent, the show cause notice directed the appellants to respond to the Commissioner of Central Excise and Service Tax 1, Commissionerate, Bengaluru. - Therefore, the Court concluded that there was no reason to interfere with the learned Single Judge’s order regarding jurisdiction.
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