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 ruled that rejection of petitioner's MEIS scrip applications was improper. Under FTP 2015-20, Export Oriented Units could claim MEIS benefits with either FIEO or EPCES registration, while exclusive EPCES registration requirement was introduced only in FTP 2023. The subsequent policy change was formalized through Circular No.78 of 2022, making EPCES membership mandatory for SEZ Units/Developers. The court found respondent's rejection order based on lack of valid RCMC during export period to be incorrect, as the mandatory EPCES registration requirement did not apply retrospectively. The impugned order was set aside and petition disposed of.
HC ruled that rejection of petitioner's MEIS scrip applications was improper. Under FTP 2015-20, Export Oriented Units could claim MEIS benefits with either FIEO or EPCES registration, while exclusive EPCES registration requirement was introduced only in FTP 2023. The subsequent policy change was formalized through Circular No.78 of 2022, making EPCES membership mandatory for SEZ Units/Developers. The court found respondent's rejection order based on lack of valid RCMC during export period to be incorrect, as the mandatory EPCES registration requirement did not apply retrospectively. The impugned order was set aside and petition disposed of.
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