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 offence in question is compoundable and the pendency of a criminal prosecution does not preclude the filing of a compounding application nor impose a limitation period based on the contested guidelines. The Court invalidated Clause 7(ii) of the relevant guideline as ultra vires the statute, relying on its prior ruling in Jayashree v. CBDT. Consequently, the HC set aside the 2nd respondent's rejection order and remanded the matter for reconsideration. The 2nd respondent is directed to admit the compounding application submitted on 15.09.2023 and decide it on merits in accordance with law, without regard to the limitation period prescribed in the struck-down clause.
The HC held that the offence in question is compoundable and the pendency of a criminal prosecution does not preclude the filing of a compounding application nor impose a limitation period based on the contested guidelines. The Court invalidated Clause 7(ii) of the relevant guideline as ultra vires the statute, relying on its prior ruling in Jayashree v. CBDT. Consequently, the HC set aside the 2nd respondent's rejection order and remanded the matter for reconsideration. The 2nd respondent is directed to admit the compounding application submitted on 15.09.2023 and decide it on merits in accordance with law, without regard to the limitation period prescribed in the struck-down clause.
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