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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HC upheld the validity of CBDT's corrigendum notification dated 5 January 2011 restricting deductions u/s 80IB(10) for slum redevelopment projects approved between 1 April 2004 and 31 March 2008. The court determined the notification properly aligned with legislative intent, as the proviso for slum redevelopment schemes was introduced prospectively from 1 April 2005. The amendment's reference to past events did not make it retrospective in nature. The petitioner's challenge claiming the notification was ultra vires failed, as the court found no legislative intention for retrospective application of the benefits. The deduction claim was rejected for non-compliance with notification conditions.
HC upheld the validity of CBDT's corrigendum notification dated 5 January 2011 restricting deductions u/s 80IB(10) for slum redevelopment projects approved between 1 April 2004 and 31 March 2008. The court determined the notification properly aligned with legislative intent, as the proviso for slum redevelopment schemes was introduced prospectively from 1 April 2005. The amendment's reference to past events did not make it retrospective in nature. The petitioner's challenge claiming the notification was ultra vires failed, as the court found no legislative intention for retrospective application of the benefits. The deduction claim was rejected for non-compliance with notification conditions.
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