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 determined the power of Tamil Nadu to levy electricity tax through inter-state open access systems. The court held that for inter-state electricity transactions, the state lacks taxation authority under Article 269A. Section 3(1)(c) of the Act cannot be interpreted to impose tax on inter-state power purchases. However, tax remains valid for captive generating plants consuming electricity for own use. The court quashed G.O.Ms.No.55 regarding open access taxation while upholding G.O.Ms.No.121, which empowers TANGEDCO to collect tax on captive generation. The ruling clarifies the state's limited taxation powers in electricity transactions, distinguishing between inter-state and intra-state consumption.
HC determined the power of Tamil Nadu to levy electricity tax through inter-state open access systems. The court held that for inter-state electricity transactions, the state lacks taxation authority under Article 269A. Section 3(1)(c) of the Act cannot be interpreted to impose tax on inter-state power purchases. However, tax remains valid for captive generating plants consuming electricity for own use. The court quashed G.O.Ms.No.55 regarding open access taxation while upholding G.O.Ms.No.121, which empowers TANGEDCO to collect tax on captive generation. The ruling clarifies the state's limited taxation powers in electricity transactions, distinguishing between inter-state and intra-state consumption.
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