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 writ petition challenging rejection of SVLDRS application on technical grounds. Petitioner filed Form-SVLDRS-1 for penalty imposed regarding two companies but authorities rejected application citing surname change from 'Shah' to 'Jain' and incorrect PAN (HUF instead of individual). Court held petitioner was eligible for SVLDRS benefits under Section 125(1) as he did not fall under exclusionary clauses A-H. Rejection on technical grounds of surname discrepancy and PAN error was unjustified when these could be corrected. Court deprecated authorities' approach in not entertaining representation and directed acceptance of corrected application with individual PAN and name 'Jitendra C. Jain', issuing Form-SVLDRS-4 within twelve weeks. Application disposed of favorably.
HC allowed the writ petition challenging rejection of SVLDRS application on technical grounds. Petitioner filed Form-SVLDRS-1 for penalty imposed regarding two companies but authorities rejected application citing surname change from 'Shah' to 'Jain' and incorrect PAN (HUF instead of individual). Court held petitioner was eligible for SVLDRS benefits under Section 125(1) as he did not fall under exclusionary clauses A-H. Rejection on technical grounds of surname discrepancy and PAN error was unjustified when these could be corrected. Court deprecated authorities' approach in not entertaining representation and directed acceptance of corrected application with individual PAN and name 'Jitendra C. Jain', issuing Form-SVLDRS-4 within twelve weeks. Application disposed of favorably.
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