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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Recovery of rebate claim - Adjusted rebate claims towards their existing liabilities - The High Court confirmed that the petitioner was eligible for rebate on their exports as per the impugned orders. Although previous orders had upheld adjustments, the High Court noted that these orders had been set aside. Consequently, there was no current demand enforceable against the petitioner, rendering the adjustment unjustified. The High Court ruled that the adjusted amounts must be refunded to the petitioner along with interest.
Recovery of rebate claim - Adjusted rebate claims towards their existing liabilities - The High Court confirmed that the petitioner was eligible for rebate on their exports as per the impugned orders. Although previous orders had upheld adjustments, the High Court noted that these orders had been set aside. Consequently, there was no current demand enforceable against the petitioner, rendering the adjustment unjustified. The High Court ruled that the adjusted amounts must be refunded to the petitioner along with interest.
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