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 held that the compounding application should be treated as filed on the original date of February 15, 2018, rather than September 24, 2020, as erroneously considered by the respondents. Consequently, the erstwhile 2014 compounding guidelines would apply instead of the 2019 guidelines. The Court directed the respondents to recompute the compounding charges payable by the petitioner based on the 2014 guidelines, considering the application date as February 15, 2018. Upon payment of the recomputed charges, the application shall be processed further in accordance with law.
The High Court held that the compounding application should be treated as filed on the original date of February 15, 2018, rather than September 24, 2020, as erroneously considered by the respondents. Consequently, the erstwhile 2014 compounding guidelines would apply instead of the 2019 guidelines. The Court directed the respondents to recompute the compounding charges payable by the petitioner based on the 2014 guidelines, considering the application date as February 15, 2018. Upon payment of the recomputed charges, the application shall be processed further in accordance with law.
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