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 petition challenging the rejection of benefits under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Multiple HCs, including Madras, Bombay, Gujarat, and Delhi, have consistently held that technical delays in payment due to COVID-19 pandemic should not disqualify applicants. The court found that denying scheme benefits would be contrary to the scheme's objectives and unjust to the eligible declarant. The impugned order rejecting the petitioner's claim was quashed, with directions to accept the payment and issue a discharge certificate. The time limit provisions were deemed directive in nature, allowing flexibility in implementation.
HC allowed the petition challenging the rejection of benefits under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Multiple HCs, including Madras, Bombay, Gujarat, and Delhi, have consistently held that technical delays in payment due to COVID-19 pandemic should not disqualify applicants. The court found that denying scheme benefits would be contrary to the scheme's objectives and unjust to the eligible declarant. The impugned order rejecting the petitioner's claim was quashed, with directions to accept the payment and issue a discharge certificate. The time limit provisions were deemed directive in nature, allowing flexibility in implementation.
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