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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Petitioners sought condonation of delay in filing belated annual returns and balance sheets without paying additional fees. The Court held that despite the existence of a scheme for condonation of delay, it had not extended the benefit to the Petitioners in its previous order dated 11.02.2021. The Court had only directed restoration of the Petitioners' names subject to payment of requisite fees, implying late fees. The Petitioners cannot now seek relief not granted in the previous order. They must pay the late fees for restoration of their names. The petition was dismissed.
Petitioners sought condonation of delay in filing belated annual returns and balance sheets without paying additional fees. The Court held that despite the existence of a scheme for condonation of delay, it had not extended the benefit to the Petitioners in its previous order dated 11.02.2021. The Court had only directed restoration of the Petitioners' names subject to payment of requisite fees, implying late fees. The Petitioners cannot now seek relief not granted in the previous order. They must pay the late fees for restoration of their names. The petition was dismissed.
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