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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Petitioner's admission of duty liability in communication dated June 19, 2019 qualified as "quantified" under SVLDRS, making them eligible for the scheme. HC quashed impugned orders rejecting petitioner's application and issued show cause notice. "Quantified" under the scheme means written communication of duty payable including admitted liability during investigation or audit. Matter remanded to Designated Committee to consider petitioner's declaration afresh as valid under "investigation, enquiry and audit" category and grant consequential relief. Petition allowed by way of remand.
Petitioner's admission of duty liability in communication dated June 19, 2019 qualified as "quantified" under SVLDRS, making them eligible for the scheme. HC quashed impugned orders rejecting petitioner's application and issued show cause notice. "Quantified" under the scheme means written communication of duty payable including admitted liability during investigation or audit. Matter remanded to Designated Committee to consider petitioner's declaration afresh as valid under "investigation, enquiry and audit" category and grant consequential relief. Petition allowed by way of remand.
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