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 revenue's attempt to reopen concluded proceedings arising from delayed employee contributions to statutory funds, holding that a subsequent change in law or later SC determinations do not constitute a proper ground for review of final adjudications. The Tribunal's order was assessed on the law prevailing when it was rendered, and a later judicial development cannot exume or revive a closed determination; at best it governs future adjudications. Given settled authority that change of law alone does not warrant re-opening concluded matters, the HC declined to remit the matter for fresh consideration and directed the parties to abide by the operative law at the time of the original decision.
The HC dismissed the revenue's attempt to reopen concluded proceedings arising from delayed employee contributions to statutory funds, holding that a subsequent change in law or later SC determinations do not constitute a proper ground for review of final adjudications. The Tribunal's order was assessed on the law prevailing when it was rendered, and a later judicial development cannot exume or revive a closed determination; at best it governs future adjudications. Given settled authority that change of law alone does not warrant re-opening concluded matters, the HC declined to remit the matter for fresh consideration and directed the parties to abide by the operative law at the time of the original decision.
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