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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The HC held that the four-year limitation period u/s 64 of the Karnataka Value Added Tax Act, 2003, pertains to the initiation of revisional proceedings by the Additional Commissioner and not the passing of the final order. In the instant case, the revisional proceedings were initiated within the four-year period from the original order's date, and thus, the Additional Commissioner had jurisdiction to pass the revisional order, even after the expiry of four years from the original order.
The HC held that the four-year limitation period u/s 64 of the Karnataka Value Added Tax Act, 2003, pertains to the initiation of revisional proceedings by the Additional Commissioner and not the passing of the final order. In the instant case, the revisional proceedings were initiated within the four-year period from the original order's date, and thus, the Additional Commissioner had jurisdiction to pass the revisional order, even after the expiry of four years from the original order.
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