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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Doctrine of merger applied to impugned order of Appellate Tribunal imposing penalty on appellant. Held that since Supreme Court's judgment on appeal against Tribunal's order, doctrine of merger renders Tribunal's order subsumed into apex court's judgment. Consequently, no question of law arises from Tribunal's order for consideration regarding perversity, jurisdiction to levy penalty or discretion exercised. Application dismissed as Tribunal's order has merged into Supreme Court's judgment under Article 136.
Doctrine of merger applied to impugned order of Appellate Tribunal imposing penalty on appellant. Held that since Supreme Court's judgment on appeal against Tribunal's order, doctrine of merger renders Tribunal's order subsumed into apex court's judgment. Consequently, no question of law arises from Tribunal's order for consideration regarding perversity, jurisdiction to levy penalty or discretion exercised. Application dismissed as Tribunal's order has merged into Supreme Court's judgment under Article 136.
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