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 directed the Income Tax Department to issue orders regarding refunds owed to Petitioners by April 15, 2025, following the department's failure to implement a 2006 ITAT order. Any refunds must be paid by April 30, 2025, with Petitioners agreeing to waive interest claims if this deadline is met. Should payment be delayed beyond this date, 6% annual interest will apply, to be recovered from the responsible officers rather than the State Exchequer. The Department must file a compliance report by May 5, 2025, with the court noting that Petitioners should not need to file fresh petitions for enforcement.
HC directed the Income Tax Department to issue orders regarding refunds owed to Petitioners by April 15, 2025, following the department's failure to implement a 2006 ITAT order. Any refunds must be paid by April 30, 2025, with Petitioners agreeing to waive interest claims if this deadline is met. Should payment be delayed beyond this date, 6% annual interest will apply, to be recovered from the responsible officers rather than the State Exchequer. The Department must file a compliance report by May 5, 2025, with the court noting that Petitioners should not need to file fresh petitions for enforcement.
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