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 dismissed the petitions and refused mandamus to direct issuance of Form C for concessional inter-State purchase of HSD, holding the petitioners are not entitled to the concessional benefit as their registration expressly limits HSD use to "running and maintenance of machinery for mining and processing for sale," which does not extend to the contested purchases; factual findings preclude issuance of Form C for HSD included in the registration. The court distinguished precedents permitting Form C for natural gas where CST continued to govern inter-State sales pending GST notifications, but concluded those authorities did not entitle these petitioners to relief. Petitions disposed.
The HC dismissed the petitions and refused mandamus to direct issuance of Form C for concessional inter-State purchase of HSD, holding the petitioners are not entitled to the concessional benefit as their registration expressly limits HSD use to "running and maintenance of machinery for mining and processing for sale," which does not extend to the contested purchases; factual findings preclude issuance of Form C for HSD included in the registration. The court distinguished precedents permitting Form C for natural gas where CST continued to govern inter-State sales pending GST notifications, but concluded those authorities did not entitle these petitioners to relief. Petitions disposed.
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