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 court held that the tax liability arising from the deletion of additions under the remand order would be less than Rs. 1,00,00,000, rendering the appeal non-maintainable as per Circular No. 17/2019. Even if the appeal were allowed and remanded to the Tribunal, the subject matter would be Rs. 50,00,000, below the prescribed monetary limit. Considering the additions disallowed and the return, the tax liability would be less than Rs. 50,00,000, precluding the appeal before the Appellate Authority. Consequently, the court dismissed both appeals in accordance with Circular No. 17/2019, finding them undeserving of acceptance due to the low tax effect.
The court held that the tax liability arising from the deletion of additions under the remand order would be less than Rs. 1,00,00,000, rendering the appeal non-maintainable as per Circular No. 17/2019. Even if the appeal were allowed and remanded to the Tribunal, the subject matter would be Rs. 50,00,000, below the prescribed monetary limit. Considering the additions disallowed and the return, the tax liability would be less than Rs. 50,00,000, precluding the appeal before the Appellate Authority. Consequently, the court dismissed both appeals in accordance with Circular No. 17/2019, finding them undeserving of acceptance due to the low tax effect.
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