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 refund claim's date of origin, not the formal application date, determines delay calculation. The court emphasized that when a refund request is made within an Income Tax Return, that date becomes the reference point for assessing delay and potential condonation. The delay from 1.4.2012 to 13.7.2012 (104 days) was considered. While the refund might be granted, no interest would be payable under section 244A due to the petitioner's eight-year delay. However, if the refund is not processed within six weeks of eligibility determination, interest would become applicable.
HC held that the refund claim's date of origin, not the formal application date, determines delay calculation. The court emphasized that when a refund request is made within an Income Tax Return, that date becomes the reference point for assessing delay and potential condonation. The delay from 1.4.2012 to 13.7.2012 (104 days) was considered. While the refund might be granted, no interest would be payable under section 244A due to the petitioner's eight-year delay. However, if the refund is not processed within six weeks of eligibility determination, interest would become applicable.
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