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 under the Direct Tax Vivad Se Vishwas Act, 2020, while the petitioner was not initially entitled to interest u/s 244A of Income Tax Act, 1961, the designated authority's approval of the scheme and subsequent refund order mandates interest payment on the withheld refund amount. The court directed respondents to pay Rs. 4,39,010/- within 12 weeks, with 12% interest applicable if payment is delayed beyond the prescribed timeline. The petition was substantially allowed, compelling the respondent to compensate the petitioner for delayed refund.
HC held that under the Direct Tax Vivad Se Vishwas Act, 2020, while the petitioner was not initially entitled to interest u/s 244A of Income Tax Act, 1961, the designated authority's approval of the scheme and subsequent refund order mandates interest payment on the withheld refund amount. The court directed respondents to pay Rs. 4,39,010/- within 12 weeks, with 12% interest applicable if payment is delayed beyond the prescribed timeline. The petition was substantially allowed, compelling the respondent to compensate the petitioner for delayed refund.
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