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 held that the communication dated 29 November 2018 was a preliminary, non-conclusive communication regarding a potential tax refund and not a statutory order. While quashing the impugned communication dated 16 June 2022, the court directed the tax authority to pass a final order determining the refund claim within eight weeks, providing the petitioner an opportunity to be heard, with all substantive contentions remaining open for consideration.
HC held that the communication dated 29 November 2018 was a preliminary, non-conclusive communication regarding a potential tax refund and not a statutory order. While quashing the impugned communication dated 16 June 2022, the court directed the tax authority to pass a final order determining the refund claim within eight weeks, providing the petitioner an opportunity to be heard, with all substantive contentions remaining open for consideration.
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