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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Stay of demand - direction as called upon the writ petitioner to make a pre-deposit of 20% - The Delhi High Court dismissed the writ petition challenging the ITAT's order, which denied interim relief to the petitioner. The core issues revolved around the petitioner’s inability to establish a prima facie case, questionable financial stringency claims, and failure to meet the burden of proof under Section 68 regarding the genuineness of certain transactions. The Court found that the ITAT and prior authorities had correctly applied the law, and the petitioner’s financial records did not substantiate their claims. - Appeal of the assessee dismissed.
Stay of demand - direction as called upon the writ petitioner to make a pre-deposit of 20% - The Delhi High Court dismissed the writ petition challenging the ITAT's order, which denied interim relief to the petitioner. The core issues revolved around the petitioner’s inability to establish a prima facie case, questionable financial stringency claims, and failure to meet the burden of proof under Section 68 regarding the genuineness of certain transactions. The Court found that the ITAT and prior authorities had correctly applied the law, and the petitioner’s financial records did not substantiate their claims. - Appeal of the assessee dismissed.
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