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 allowed the writ appeal, reversed the writ court's order and held the SVLDRS declaration and resultant discharge certificate void ab initio due to material misrepresentation: the declarant knowingly misclassified the matter as "voluntary disclosure" despite ongoing investigations, thus suppressing a material fact under the Scheme. The Court found investigation activity and statements recorded both before and after the declaration, reaffirmed Circular guidance requiring veracity, and determined departmental lapses in coordination did not cure non-disclosure. Consequentially the application under the Scheme is presumed never filed and the Designated Committee's issuance of Form SVLDRS-3 and the discharge certificate are set aside.
The HC allowed the writ appeal, reversed the writ court's order and held the SVLDRS declaration and resultant discharge certificate void ab initio due to material misrepresentation: the declarant knowingly misclassified the matter as "voluntary disclosure" despite ongoing investigations, thus suppressing a material fact under the Scheme. The Court found investigation activity and statements recorded both before and after the declaration, reaffirmed Circular guidance requiring veracity, and determined departmental lapses in coordination did not cure non-disclosure. Consequentially the application under the Scheme is presumed never filed and the Designated Committee's issuance of Form SVLDRS-3 and the discharge certificate are set aside.
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