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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Levy of penalty - discrepancy in turnover - requirement of adding gross profit and freight charges to the purchase value - The Madras High Court concluded that the levy of penalty u/s 27(3) of the TNVAT Act was unjustified due to the absence of a finding of willful nondisclosure of assessable turnover. The petitioner acted on the method suggested by enforcement officers, and the discrepancy in turnover did not amount to willful nondisclosure. Consequently, the Court set aside the impugned orders regarding the penalty, while the remaining portions of the assessment orders remained undisturbed.
Levy of penalty - discrepancy in turnover - requirement of adding gross profit and freight charges to the purchase value - The Madras High Court concluded that the levy of penalty u/s 27(3) of the TNVAT Act was unjustified due to the absence of a finding of willful nondisclosure of assessable turnover. The petitioner acted on the method suggested by enforcement officers, and the discrepancy in turnover did not amount to willful nondisclosure. Consequently, the Court set aside the impugned orders regarding the penalty, while the remaining portions of the assessment orders remained undisturbed.
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