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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The HC allowed petitioner's writ petition challenging rejection of benefits under Sabka Vishwas Legacy Dispute Resolution Scheme 2019. Respondents denied benefits solely because scheme deadline had expired, despite petitioner's COVID-related payment difficulties. The HC relied on Supreme Court limitation extension judgments and favorable High Court decisions from Madras, Bombay, Gujarat, and Delhi granting SVLDRS benefits in COVID circumstances, even for post-deadline payments. The court held that denying scheme benefits would contradict the scheme's objective of liquidating past central excise and service tax disputes before GST implementation and would cause injustice to an otherwise eligible declarant. Following Madras HC precedent in N. Sundarajan, the court determined scheme provisions were directive rather than mandatory. The impugned rejection order and demand notices were quashed, with directions issued to accept petitioner's payment and issue discharge certificate.
The HC allowed petitioner's writ petition challenging rejection of benefits under Sabka Vishwas Legacy Dispute Resolution Scheme 2019. Respondents denied benefits solely because scheme deadline had expired, despite petitioner's COVID-related payment difficulties. The HC relied on Supreme Court limitation extension judgments and favorable High Court decisions from Madras, Bombay, Gujarat, and Delhi granting SVLDRS benefits in COVID circumstances, even for post-deadline payments. The court held that denying scheme benefits would contradict the scheme's objective of liquidating past central excise and service tax disputes before GST implementation and would cause injustice to an otherwise eligible declarant. Following Madras HC precedent in N. Sundarajan, the court determined scheme provisions were directive rather than mandatory. The impugned rejection order and demand notices were quashed, with directions issued to accept petitioner's payment and issue discharge certificate.
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