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 2003 Policy of the Punjab Government granted exemption from payment of Market fee under Clause (i) of 11.4.2, but did not specifically exempt Rural Development fee. The High Court erred in dismissing the petition based on the State counsel's submission that Market fee covered Rural Development fee, without adjudicating the issue on merits. The 2003 Policy does not exempt Rural Development fees, and assuming such exemption would broaden the policy's scope unintentionally. Market fees and Rural Development fees are distinct under different statutory frameworks and cannot be equated. No unit other than approved Mega Projects has been allowed exemption from Rural Development fee. The respondent, M/s Punjab Spintex Limited, not being a Mega Project, is ineligible for such exemption. The impugned order is set aside, and the appeal is allowed.
The 2003 Policy of the Punjab Government granted exemption from payment of Market fee under Clause (i) of 11.4.2, but did not specifically exempt Rural Development fee. The High Court erred in dismissing the petition based on the State counsel's submission that Market fee covered Rural Development fee, without adjudicating the issue on merits. The 2003 Policy does not exempt Rural Development fees, and assuming such exemption would broaden the policy's scope unintentionally. Market fees and Rural Development fees are distinct under different statutory frameworks and cannot be equated. No unit other than approved Mega Projects has been allowed exemption from Rural Development fee. The respondent, M/s Punjab Spintex Limited, not being a Mega Project, is ineligible for such exemption. The impugned order is set aside, and the appeal is allowed.
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