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 computation methodology under the Jharkhand Amnesty Scheme 2022, clarifying the distinction between 'admitted tax' and 'disputed amount.' The Settlement Officer's approach of deducting pre-deposit before applying waiver percentages was deemed incorrect. While the petitioner demonstrated a potential loss of Rs. 1,32,03,446 due to incorrect scheme application, they were bound by their revised computation submitted during appellate proceedings. Following the principle of liberal interpretation for beneficial legislation, as established in Mother Superior Adoration Convent case, the court granted relief. The petitioner was awarded a refund of Rs. 1,18,02,056 with 6% annual interest from deposit date until refund disbursement.
HC determined the computation methodology under the Jharkhand Amnesty Scheme 2022, clarifying the distinction between 'admitted tax' and 'disputed amount.' The Settlement Officer's approach of deducting pre-deposit before applying waiver percentages was deemed incorrect. While the petitioner demonstrated a potential loss of Rs. 1,32,03,446 due to incorrect scheme application, they were bound by their revised computation submitted during appellate proceedings. Following the principle of liberal interpretation for beneficial legislation, as established in Mother Superior Adoration Convent case, the court granted relief. The petitioner was awarded a refund of Rs. 1,18,02,056 with 6% annual interest from deposit date until refund disbursement.
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