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 determined the petitioner's declaration under SVLDRS-2019 was incorrectly filed under "litigation category" instead of "Amount in Arrears Category." While the discharge certificate cannot be revoked under Section 129(2)(c), the Designated Authority has powers to correct mistakes if misled by improper declarations. The court found no legal provision under Finance Act 1994 allowing recovery of company's tax dues from directors' personal accounts, thus quashing the bank account attachment order. The recovered amount of Rs. 22,00,000 can be adjusted against deficit amount subject to director's consent. Petitioner remains eligible for relief under Section 124(1)(c)(ii) rather than 124(1)(a)(ii), contingent upon payment of correct amount with interest.
HC determined the petitioner's declaration under SVLDRS-2019 was incorrectly filed under "litigation category" instead of "Amount in Arrears Category." While the discharge certificate cannot be revoked under Section 129(2)(c), the Designated Authority has powers to correct mistakes if misled by improper declarations. The court found no legal provision under Finance Act 1994 allowing recovery of company's tax dues from directors' personal accounts, thus quashing the bank account attachment order. The recovered amount of Rs. 22,00,000 can be adjusted against deficit amount subject to director's consent. Petitioner remains eligible for relief under Section 124(1)(c)(ii) rather than 124(1)(a)(ii), contingent upon payment of correct amount with interest.
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