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 dismissed the refund claim, holding that no writ of mandamus could be issued to process the petitioner's refund application for AY 2020-21. The court acknowledged the respondents' communications indicating the refund was withheld due to CASS scrutiny criteria for AY 2023-24. While the court agreed that communications should have been served earlier to the petitioner, it ultimately found no further substantive grounds to challenge the decision, effectively leaving the refund claim unresolved and permitting the respondents to continue their scrutiny process.
HC dismissed the refund claim, holding that no writ of mandamus could be issued to process the petitioner's refund application for AY 2020-21. The court acknowledged the respondents' communications indicating the refund was withheld due to CASS scrutiny criteria for AY 2023-24. While the court agreed that communications should have been served earlier to the petitioner, it ultimately found no further substantive grounds to challenge the decision, effectively leaving the refund claim unresolved and permitting the respondents to continue their scrutiny process.
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