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 SC dismissed the Special Leave Petition filed by the petitioners for gross unexplained delay of 457 days and on merits, thereby upholding the High Court's grant of relief. The HC had directed the respondent to allow interest on the refund claim relating to compensation for acquisition of the petitioners' agricultural land, holding that TDS was wrongly deducted under s.194C instead of s.194A and that interest under s.244A of the Act, 1961 is payable from the date of deposit of TDS until actual refund; that direction was to be implemented within 12 weeks. The SLP is dismissed; the HC order directing interest payment remains binding and executable.
The SC dismissed the Special Leave Petition filed by the petitioners for gross unexplained delay of 457 days and on merits, thereby upholding the High Court's grant of relief. The HC had directed the respondent to allow interest on the refund claim relating to compensation for acquisition of the petitioners' agricultural land, holding that TDS was wrongly deducted under s.194C instead of s.194A and that interest under s.244A of the Act, 1961 is payable from the date of deposit of TDS until actual refund; that direction was to be implemented within 12 weeks. The SLP is dismissed; the HC order directing interest payment remains binding and executable.
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