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 allowed the petitioner's challenge to the rejected settlement under the DTVSV Scheme. The court held that the dispute falls within the scope of the Finance Act provisions, and the designated authority's rejection was erroneous. The key reasoning emphasized that an assessee's entitlement to carry forward losses for a specific assessment year is distinct from claiming those losses in subsequent years. The court found that the petitioner's inability to claim carry forward loss in AY 2023-24 does not preclude settlement of the dispute for AY 2022-23. Consequently, the court directed reconsideration of the settlement application under Rule 9(1) of the DTVSV Rules.
HC allowed the petitioner's challenge to the rejected settlement under the DTVSV Scheme. The court held that the dispute falls within the scope of the Finance Act provisions, and the designated authority's rejection was erroneous. The key reasoning emphasized that an assessee's entitlement to carry forward losses for a specific assessment year is distinct from claiming those losses in subsequent years. The court found that the petitioner's inability to claim carry forward loss in AY 2023-24 does not preclude settlement of the dispute for AY 2022-23. Consequently, the court directed reconsideration of the settlement application under Rule 9(1) of the DTVSV Rules.
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