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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This case deals with the deduction u/s 80DD of the Income Tax Act for maintaining and providing medical treatment to a dependent person with disability. The key points are: The petitioner sought retrospective application of an amendment to Section 80DD, allowing deduction for payment of annuity or lump sum for the benefit of a disabled dependent after the subscriber's death. The court rejected the plea for retrospective application, as it would go against the object of the insurance policy taken for the disabled person's benefit after the subscriber's demise. Giving retrospective effect would remove the substratum of the insurance contract, a commercial agreement with specific terms and conditions. The court considered various laws and conventions related to the rights and welfare of persons with disabilities. The grievance of the petitioner was addressed prospectively through the amendment to Section 80DD, as per the court's earlier order.
This case deals with the deduction u/s 80DD of the Income Tax Act for maintaining and providing medical treatment to a dependent person with disability. The key points are: The petitioner sought retrospective application of an amendment to Section 80DD, allowing deduction for payment of annuity or lump sum for the benefit of a disabled dependent after the subscriber's death. The court rejected the plea for retrospective application, as it would go against the object of the insurance policy taken for the disabled person's benefit after the subscriber's demise. Giving retrospective effect would remove the substratum of the insurance contract, a commercial agreement with specific terms and conditions. The court considered various laws and conventions related to the rights and welfare of persons with disabilities. The grievance of the petitioner was addressed prospectively through the amendment to Section 80DD, as per the court's earlier order.
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