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 SC dismissed the petition challenging the HC's order quashing proceedings under sections 276B read with 278AA of the Income Tax Act against appellants operating an educational institution for delayed TDS remittance. The HC found the delay was inadvertent, caused by staff maternity leave, and promptly rectified by subsequent timely deduction and payment. The Court affirmed the HC's exercise of discretion to quash proceedings based on the appellants' conduct, holding no reason to interfere under Article 136. The SC left open any question of law and dismissed the petition with pending applications.
The SC dismissed the petition challenging the HC's order quashing proceedings under sections 276B read with 278AA of the Income Tax Act against appellants operating an educational institution for delayed TDS remittance. The HC found the delay was inadvertent, caused by staff maternity leave, and promptly rectified by subsequent timely deduction and payment. The Court affirmed the HC's exercise of discretion to quash proceedings based on the appellants' conduct, holding no reason to interfere under Article 136. The SC left open any question of law and dismissed the petition with pending applications.
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