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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Service tax recovery from foreign government agencies for statutory fees/licenses - Petitioner's declaration under SVLDRS rejected - HC held pre-deposit amount during appeal proceedings not considered for tax dues calculation u/s 124(1) but deducted while issuing statement under 124(2) - CBIC circular clarified relief under 124(1)(c) applied to net outstanding dues after deducting pre-deposit - Petitioner rightly deducted pre-deposit from net eligible amount - Directed to appropriate Rs. 9,86,360/- from deposited Rs. 11,22,934/-, return remaining Rs. 2,27,622/- by rectified SVLDRS-3 and issue SVLDRS-4 - Petition allowed.
Service tax recovery from foreign government agencies for statutory fees/licenses - Petitioner's declaration under SVLDRS rejected - HC held pre-deposit amount during appeal proceedings not considered for tax dues calculation u/s 124(1) but deducted while issuing statement under 124(2) - CBIC circular clarified relief under 124(1)(c) applied to net outstanding dues after deducting pre-deposit - Petitioner rightly deducted pre-deposit from net eligible amount - Directed to appropriate Rs. 9,86,360/- from deposited Rs. 11,22,934/-, return remaining Rs. 2,27,622/- by rectified SVLDRS-3 and issue SVLDRS-4 - Petition allowed.
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