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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Simultaneous investigation by the Central and State GST authorities - The petitioner argued that the DGGI's actions violated a circular mandating coordination between Central and State tax authorities in investigations. They contended that since the State tax authority had already initiated proceedings for the same period, the DGGI should not have conducted parallel proceedings. The High Court declined to express a definite opinion on the matter, as it found that the petitioner had not raised the jurisdictional issue when responding to the summons. The Court emphasized the petitioner's right to respond to the show cause-cum-demand notice issued by the DGGI and take appropriate recourse under the CGST Act.
Simultaneous investigation by the Central and State GST authorities - The petitioner argued that the DGGI's actions violated a circular mandating coordination between Central and State tax authorities in investigations. They contended that since the State tax authority had already initiated proceedings for the same period, the DGGI should not have conducted parallel proceedings. The High Court declined to express a definite opinion on the matter, as it found that the petitioner had not raised the jurisdictional issue when responding to the summons. The Court emphasized the petitioner's right to respond to the show cause-cum-demand notice issued by the DGGI and take appropriate recourse under the CGST Act.
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