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 set aside the orders rejecting the petitioner's refund claims for excess tax paid in different assessment years on the ground of time limitation. The Court observed that Rule 29 prescribes the time limit for filing refund claims, but the proviso empowers the authority to admit delayed claims if sufficient cause is shown. The impugned orders did not reflect if the petitioner was given an opportunity to explain the delay. The respondents did not dispute the petitioner's entitlement to refund or the assessment proceedings referred to. The Court remanded the matter to the concerned authority, permitting the petitioner to explain the causes of delay in filing the refund applications.
The High Court set aside the orders rejecting the petitioner's refund claims for excess tax paid in different assessment years on the ground of time limitation. The Court observed that Rule 29 prescribes the time limit for filing refund claims, but the proviso empowers the authority to admit delayed claims if sufficient cause is shown. The impugned orders did not reflect if the petitioner was given an opportunity to explain the delay. The respondents did not dispute the petitioner's entitlement to refund or the assessment proceedings referred to. The Court remanded the matter to the concerned authority, permitting the petitioner to explain the causes of delay in filing the refund applications.
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