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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The High Court addressed the issue of liability to pay GST based on a Board resolution. The Court found that the agreement's scope of work included all taxes, so the contractor cannot claim additional GST. The government's reduction of GST on works contracts balanced pre and post-GST taxes. The petitioner was required to execute a supplemental agreement at a reduced value. The effective date of GST was considered, and the petitioner failed to provide evidence of paying GST or claiming input tax credit. Due to the arbitration clause in the agreement, the Court could not issue the direction sought in the writ petition. The petitioner was given the option to invoke arbitration within four weeks. The Writ Petition was disposed of accordingly.
The High Court addressed the issue of liability to pay GST based on a Board resolution. The Court found that the agreement's scope of work included all taxes, so the contractor cannot claim additional GST. The government's reduction of GST on works contracts balanced pre and post-GST taxes. The petitioner was required to execute a supplemental agreement at a reduced value. The effective date of GST was considered, and the petitioner failed to provide evidence of paying GST or claiming input tax credit. Due to the arbitration clause in the agreement, the Court could not issue the direction sought in the writ petition. The petitioner was given the option to invoke arbitration within four weeks. The Writ Petition was disposed of accordingly.
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