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 upheld that interest liability on penalties imposed under the SEBI Act arises from the expiry of the compliance period specified in the adjudication order, here 45 days from 28.08.2014, not from subsequent demand notices. Section 28A of the SEBI Act, along with Explanation 4 inserted in 2019, clarifies that interest accrues from the date the amount became payable, which is triggered by the adjudication order itself when it specifies the payment timeline. The interest is compensatory, aimed at compensating revenue loss due to delayed payment, not punitive. Separate demand notices are redundant where the adjudication order fixes the payment period. The appellants' contention to defer interest liability until formal demand notices is rejected as it would undermine enforcement and revenue protection. The appeals were dismissed, directing payment of interest as computed by the respondent within 15 days, with no costs awarded.
The SC upheld that interest liability on penalties imposed under the SEBI Act arises from the expiry of the compliance period specified in the adjudication order, here 45 days from 28.08.2014, not from subsequent demand notices. Section 28A of the SEBI Act, along with Explanation 4 inserted in 2019, clarifies that interest accrues from the date the amount became payable, which is triggered by the adjudication order itself when it specifies the payment timeline. The interest is compensatory, aimed at compensating revenue loss due to delayed payment, not punitive. Separate demand notices are redundant where the adjudication order fixes the payment period. The appellants' contention to defer interest liability until formal demand notices is rejected as it would undermine enforcement and revenue protection. The appeals were dismissed, directing payment of interest as computed by the respondent within 15 days, with no costs awarded.
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