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 directed that upon the petitioner producing all necessary materials for closure of the CGDS account before the respondent authorities, the respondents shall decide on the matter and pass final orders within four weeks. The commencement of proceedings will be intimated to the petitioner by the concerned respondent within three weeks. The issue regarding transfer of income tax jurisdiction from Shillong to Kolkata was no longer resisted.
The court directed that upon the petitioner producing all necessary materials for closure of the CGDS account before the respondent authorities, the respondents shall decide on the matter and pass final orders within four weeks. The commencement of proceedings will be intimated to the petitioner by the concerned respondent within three weeks. The issue regarding transfer of income tax jurisdiction from Shillong to Kolkata was no longer resisted.
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