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 appeal filed by the Revenue was dismissed due to the amount involved being less than the permitted monetary limit for filing an appeal before the Tribunal. The case pertained to the seizure of gold from a passenger's personal baggage. The High Court's order dated 08.08.2019 directed the dismissal based on monetary limits, which was to be followed. However, the High Court's subsequent order dated 29.03.2023 in a related case permitted the Revenue to raise objections regarding the maintainability of the appeal before the Appellate Tribunal. Consequently, the Appellate Tribunal dismissed the Revenue's appeal as not maintainable, adhering to the specific directions in the latter High Court order.
The appeal filed by the Revenue was dismissed due to the amount involved being less than the permitted monetary limit for filing an appeal before the Tribunal. The case pertained to the seizure of gold from a passenger's personal baggage. The High Court's order dated 08.08.2019 directed the dismissal based on monetary limits, which was to be followed. However, the High Court's subsequent order dated 29.03.2023 in a related case permitted the Revenue to raise objections regarding the maintainability of the appeal before the Appellate Tribunal. Consequently, the Appellate Tribunal dismissed the Revenue's appeal as not maintainable, adhering to the specific directions in the latter High Court order.
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