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 held that the petitioner's payment of the third installment under the Income Declaration Scheme, 2016, was effectively made on or before the due date despite the delayed credit in the treasury's account. The petitioner deposited the amount with a cooperative bank by the deadline, and the subsequent delay in transfer to the respondent's account was attributable to interbank processing, not petitioner's fault. Consequently, the petitioner was entitled to the benefits of the Scheme, and the rejection of the application and non-issuance of Form 4 were set aside. The petitions were allowed.
The HC held that the petitioner's payment of the third installment under the Income Declaration Scheme, 2016, was effectively made on or before the due date despite the delayed credit in the treasury's account. The petitioner deposited the amount with a cooperative bank by the deadline, and the subsequent delay in transfer to the respondent's account was attributable to interbank processing, not petitioner's fault. Consequently, the petitioner was entitled to the benefits of the Scheme, and the rejection of the application and non-issuance of Form 4 were set aside. The petitions were allowed.
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