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 HC quashed the final order dated 31 January 2023 and the show cause notice (SCN) proceedings emanating from the impugned SCN dated 21 April 2011, after holding that the adjudication proceedings pending for almost 12 years were vitiated in law. The HC observed that although the petitioner was blamed for seeking repeated adjournments, the principal reason for the failure to conclude the proceedings expeditiously was the matter remaining in the call book for many years, as admitted by the respondents themselves.
The HC quashed the final order dated 31 January 2023 and the show cause notice (SCN) proceedings emanating from the impugned SCN dated 21 April 2011, after holding that the adjudication proceedings pending for almost 12 years were vitiated in law. The HC observed that although the petitioner was blamed for seeking repeated adjournments, the principal reason for the failure to conclude the proceedings expeditiously was the matter remaining in the call book for many years, as admitted by the respondents themselves.
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