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 AT dismissed the review applications filed for waiver of pre-deposit of penalties under FERA. The appellants' failure to comply with the deposit order justified the dismissal of their appeals. The AT found the review petitions failed to meet the conditions under CPC and did not fall within the principles culled out in the Kamal Sengupta judgment after unfavorable orders from higher courts. As held in Ram Kishor Gupta judgment, there was no question of filing reviews of the order affirmed by higher judicial fora. The AT concluded the review petitions had no merit and were dismissed.
The AT dismissed the review applications filed for waiver of pre-deposit of penalties under FERA. The appellants' failure to comply with the deposit order justified the dismissal of their appeals. The AT found the review petitions failed to meet the conditions under CPC and did not fall within the principles culled out in the Kamal Sengupta judgment after unfavorable orders from higher courts. As held in Ram Kishor Gupta judgment, there was no question of filing reviews of the order affirmed by higher judicial fora. The AT concluded the review petitions had no merit and were dismissed.
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