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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Entitlement for refund of input credit in cash, which was neither transitioned in accordance with TRAN-1 (GST) procedure into the new regime nor got reflected in the ER-1 or revised ER-1 return post 01.07.2017 - The tribunal meticulously analyzed the arguments, focusing on the statutory provisions of Section 142(3) of the CGST Act, which pertains to the treatment of unutilized credits during the transition to GST. The tribunal acknowledged the appellant's argument but highlighted that the legislative intent of the GST transition provisions does not automatically allow refunds of credits that were non-refundable under the erstwhile laws.
Entitlement for refund of input credit in cash, which was neither transitioned in accordance with TRAN-1 (GST) procedure into the new regime nor got reflected in the ER-1 or revised ER-1 return post 01.07.2017 - The tribunal meticulously analyzed the arguments, focusing on the statutory provisions of Section 142(3) of the CGST Act, which pertains to the treatment of unutilized credits during the transition to GST. The tribunal acknowledged the appellant's argument but highlighted that the legislative intent of the GST transition provisions does not automatically allow refunds of credits that were non-refundable under the erstwhile laws.
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