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 dismissed appellants' application for de-freezing bank accounts, clarifying that no debit freeze exists according to the Enforcement Directorate (ED). The Court ruled that appellants are free to operate their accounts in accordance with law. ED was directed to communicate this position to the respective banks within five working days, including a copy of the order to lift any debit freeze. However, the Court specified that appeals challenging the attachment orders filed before the Tribunal shall be decided on their own merits. The appeal was accordingly disposed of.
The HC dismissed appellants' application for de-freezing bank accounts, clarifying that no debit freeze exists according to the Enforcement Directorate (ED). The Court ruled that appellants are free to operate their accounts in accordance with law. ED was directed to communicate this position to the respective banks within five working days, including a copy of the order to lift any debit freeze. However, the Court specified that appeals challenging the attachment orders filed before the Tribunal shall be decided on their own merits. The appeal was accordingly disposed of.
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