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 the petitioner’s claim for budgetary support - Violation of principles of natural justice - The court emphasized that the Budgetary Support Scheme mandated quarterly claims, which the petitioner failed to adhere to by submitting separate claims for July and August 2017. Regarding the interpretation of circulars, the court determined that they were consistent with the scheme and aimed to facilitate the verification process. However, the petitioner's failure to comply with the prescribed procedure led to the rejection of their claim. Additionally, the court affirmed that the correct method of calculating budgetary support required quarterly claims, and the petitioner's attempt to claim support separately for July and August 2017 resulted in a flawed calculation.
Rejection of the petitioner’s claim for budgetary support - Violation of principles of natural justice - The court emphasized that the Budgetary Support Scheme mandated quarterly claims, which the petitioner failed to adhere to by submitting separate claims for July and August 2017. Regarding the interpretation of circulars, the court determined that they were consistent with the scheme and aimed to facilitate the verification process. However, the petitioner's failure to comply with the prescribed procedure led to the rejection of their claim. Additionally, the court affirmed that the correct method of calculating budgetary support required quarterly claims, and the petitioner's attempt to claim support separately for July and August 2017 resulted in a flawed calculation.
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