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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HC held that the State tax authority possesses statutory power under the non-obstante provision of Section 44 to recover tax dues by attaching amounts owed to a dealer, which includes subsidy payments due to an industry under central industrial policies once those claims are processed, approved by the competent State Committees, sanctioned by the DIPP and released via the designated disbursing agency. The court construed "any person from whom any amount is due or may become due" and "any person who holds or may subsequently hold" to encompass persons holding sanctioned subsidy proceeds, enabling recovery forthwith upon such amounts becoming due or held. The writ petitions are disposed of.
HC held that the State tax authority possesses statutory power under the non-obstante provision of Section 44 to recover tax dues by attaching amounts owed to a dealer, which includes subsidy payments due to an industry under central industrial policies once those claims are processed, approved by the competent State Committees, sanctioned by the DIPP and released via the designated disbursing agency. The court construed "any person from whom any amount is due or may become due" and "any person who holds or may subsequently hold" to encompass persons holding sanctioned subsidy proceeds, enabling recovery forthwith upon such amounts becoming due or held. The writ petitions are disposed of.
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