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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Imposition of 100% penalty - Late Filing of Writ Petition - Petitioner seeks an opportunity to contest the liability towards penalty by way of statutory appeal - The High Court acknowledged that the petitioner had indeed paid the entire tax and interest liability. Considering this, and the fact that the petitioner had not filed an appeal earlier due to the intention to discharge liability, the Court deemed it just and appropriate to permit the petitioner to file a statutory appeal specifically concerning the penalty.
Imposition of 100% penalty - Late Filing of Writ Petition - Petitioner seeks an opportunity to contest the liability towards penalty by way of statutory appeal - The High Court acknowledged that the petitioner had indeed paid the entire tax and interest liability. Considering this, and the fact that the petitioner had not filed an appeal earlier due to the intention to discharge liability, the Court deemed it just and appropriate to permit the petitioner to file a statutory appeal specifically concerning the penalty.
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