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 High Court dismissed the petition seeking direction to issue a discharge certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. The petitioner had availed the scheme's benefit but failed to make the payment within the prescribed time limit of June 30, 2020. The court held that extending the payment date would amount to modifying the scheme, which is impermissible under the law. The Supreme Court's decision in M/S. YASHI CONSTRUCTIONS VERSUS UNION OF INDIA & ORS. was cited, which stated that a person availing a scheme's benefits must strictly abide by its terms and conditions. Since the petitioner did not comply with the scheme's terms, the court found no reason to interfere and dismissed the petition.
The High Court dismissed the petition seeking direction to issue a discharge certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. The petitioner had availed the scheme's benefit but failed to make the payment within the prescribed time limit of June 30, 2020. The court held that extending the payment date would amount to modifying the scheme, which is impermissible under the law. The Supreme Court's decision in M/S. YASHI CONSTRUCTIONS VERSUS UNION OF INDIA & ORS. was cited, which stated that a person availing a scheme's benefits must strictly abide by its terms and conditions. Since the petitioner did not comply with the scheme's terms, the court found no reason to interfere and dismissed the petition.
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