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 set aside the order of the 1st respondent/Interim Board for Settlement-II rejecting the petitioner's third settlement application under section 245C. The Settlement Board had found non-disclosure of income relating to an alleged Rs. 18 Crores transaction from Smt. VK Sasikala, concluding the petitioner did not make full and true disclosure. However, the Adjudicating Authority had previously examined the transaction and concluded no such amount was received, a finding not considered by the Settlement Board. The HC held that the Settlement Board must base rejection on valid reasons and remanded the matter for fresh consideration in light of the Adjudicating Authority's findings. The impugned rejection order was quashed, and the 1st respondent was directed to reconsider the application afresh.
The HC set aside the order of the 1st respondent/Interim Board for Settlement-II rejecting the petitioner's third settlement application under section 245C. The Settlement Board had found non-disclosure of income relating to an alleged Rs. 18 Crores transaction from Smt. VK Sasikala, concluding the petitioner did not make full and true disclosure. However, the Adjudicating Authority had previously examined the transaction and concluded no such amount was received, a finding not considered by the Settlement Board. The HC held that the Settlement Board must base rejection on valid reasons and remanded the matter for fresh consideration in light of the Adjudicating Authority's findings. The impugned rejection order was quashed, and the 1st respondent was directed to reconsider the application afresh.
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