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HC determined that revenue appeals below monetary threshold of Rs. 2 crores must be withdrawn per CBDT circulars, rejecting argument for selective application. Court held that withdrawal provisions in circulars explicitly apply to pending appeals, while exceptions for filing new appeals below monetary limits are prospective from March 15, 2024. Following precedents in Anonymous v. Anonymous and related cases, HC disposed of appeals as revenue counsel lacked instructions to withdraw, despite clear directive in circulars. Court emphasized holistic interpretation of circulars, confirming retrospective application for withdrawal of pending matters while maintaining prospective application for new filings.
HC determined that revenue appeals below monetary threshold of Rs. 2 crores must be withdrawn per CBDT circulars, rejecting argument for selective application. Court held that withdrawal provisions in circulars explicitly apply to pending appeals, while exceptions for filing new appeals below monetary limits are prospective from March 15, 2024. Following precedents in Anonymous v. Anonymous and related cases, HC disposed of appeals as revenue counsel lacked instructions to withdraw, despite clear directive in circulars. Court emphasized holistic interpretation of circulars, confirming retrospective application for withdrawal of pending matters while maintaining prospective application for new filings.
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