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 considered a challenge to an assessment order regarding the levy of interest u/s 22 of the AGST Act, 1993. The matter was previously remanded by the Supreme Court to determine if the company had collected sales tax from consumers and if so, to deposit the tax amount with interest. Initial notices were issued in 1996, leading to a show cause notice in March 1996 and an assessment order in July 2001. Despite the balance being nil post-Supreme Court order, interest was imposed citing late payment. The High Court found the imposition of interest unwarranted and disposed of the petition accordingly.
The High Court considered a challenge to an assessment order regarding the levy of interest u/s 22 of the AGST Act, 1993. The matter was previously remanded by the Supreme Court to determine if the company had collected sales tax from consumers and if so, to deposit the tax amount with interest. Initial notices were issued in 1996, leading to a show cause notice in March 1996 and an assessment order in July 2001. Despite the balance being nil post-Supreme Court order, interest was imposed citing late payment. The High Court found the imposition of interest unwarranted and disposed of the petition accordingly.
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