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 appellants made the payment on 25.08.2020 under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS). The dispute was whether this payment would entitle them to discharge obligations under SVLDRS and avail amnesty from interest and penalty. The CESTAT held that the appellants were trying to pay before 30.06.2020, but faced technical glitches. The Department was exploring possibilities to extend the scheme for those issued SVLDRS-3 before 30.06.2020 but couldn't pay. The Supreme Court had extended limitation periods due to the pandemic. The Madras High Court held that the time limit for SVLDRS payment was extended till 30.09.2020. Since the appellants discharged their liability within this permissible time, they were entitled to a discharge certificate under SVLDRS-4, without interest or penalty. The appeal was allowed.
The appellants made the payment on 25.08.2020 under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS). The dispute was whether this payment would entitle them to discharge obligations under SVLDRS and avail amnesty from interest and penalty. The CESTAT held that the appellants were trying to pay before 30.06.2020, but faced technical glitches. The Department was exploring possibilities to extend the scheme for those issued SVLDRS-3 before 30.06.2020 but couldn't pay. The Supreme Court had extended limitation periods due to the pandemic. The Madras High Court held that the time limit for SVLDRS payment was extended till 30.09.2020. Since the appellants discharged their liability within this permissible time, they were entitled to a discharge certificate under SVLDRS-4, without interest or penalty. The appeal was allowed.
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