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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Provisional attachment orders u/s 281B were passed on 10.01.2024, valid for six months. The respondents were empowered to extend the provisional attachment for two more years under proviso to Section 281B(2), but failed to do so before expiry. Consequently, the provisional attachment orders ceased to have effect after six months on 10.07.2024, as no extension order was passed. Once an attachment order ceases, its continuation is impermissible unless extended per Section 281B(2) proviso. The HC's interim order of 15.02.2024 continues as long as the impugned provisional attachment order existed.
Provisional attachment orders u/s 281B were passed on 10.01.2024, valid for six months. The respondents were empowered to extend the provisional attachment for two more years under proviso to Section 281B(2), but failed to do so before expiry. Consequently, the provisional attachment orders ceased to have effect after six months on 10.07.2024, as no extension order was passed. Once an attachment order ceases, its continuation is impermissible unless extended per Section 281B(2) proviso. The HC's interim order of 15.02.2024 continues as long as the impugned provisional attachment order existed.
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