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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The HC set aside the rejection of the petitioner's application under the Direct Tax Vivad Se Vishwas Scheme, 2024. The Court held that since the tax liability was under dispute before the Appellate Authority, the petitioner qualified for the scheme regardless of potential jurisdictional issues. The Court found it improper for respondents to reject the application on jurisdictional grounds that should be determined by the Appellate Authority. The HC directed the first respondent to accept the petitioner's application filed on October 4, 2024, and issue a discharge certificate in accordance with DTVSV Scheme provisions.
The HC set aside the rejection of the petitioner's application under the Direct Tax Vivad Se Vishwas Scheme, 2024. The Court held that since the tax liability was under dispute before the Appellate Authority, the petitioner qualified for the scheme regardless of potential jurisdictional issues. The Court found it improper for respondents to reject the application on jurisdictional grounds that should be determined by the Appellate Authority. The HC directed the first respondent to accept the petitioner's application filed on October 4, 2024, and issue a discharge certificate in accordance with DTVSV Scheme provisions.
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