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 petitioner's Miscellaneous Application was not pending as on 31st January 2020, the specified date for eligibility under the VSV Scheme. However, the Tribunal subsequently recalled its order dismissing the petitioner's appeal filed in 2015, effectively restoring the appeal to a pending status as of 31st January 2020. Consequently, the petitioner qualifies as an appellant eligible to file a declaration u/ss 3 and 4 of the VSV Act on the specified date. The respondent authority's rejection of the petitioner's declaration is untenable and quashed. The authority is directed to consider and process the petitioner's declaration within 12 weeks.
The petitioner's Miscellaneous Application was not pending as on 31st January 2020, the specified date for eligibility under the VSV Scheme. However, the Tribunal subsequently recalled its order dismissing the petitioner's appeal filed in 2015, effectively restoring the appeal to a pending status as of 31st January 2020. Consequently, the petitioner qualifies as an appellant eligible to file a declaration u/ss 3 and 4 of the VSV Act on the specified date. The respondent authority's rejection of the petitioner's declaration is untenable and quashed. The authority is directed to consider and process the petitioner's declaration within 12 weeks.
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