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 allowed the writ, holding that rejection of the Petitioner's SVLDR-1 declaration without affording an opportunity of hearing violated principles of natural justice. The impugned e-mail rejection dated 6 February 2020 was quashed and set aside, and the declaration was ordered to be accepted with the duty liability quantified at Rs. 1,06,21,929/-. The Respondents were directed to compute the revised payable amount under the SVLDR scheme, deducting a verified pre-deposit of Rs. 29,72,500/-. The petition was disposed of, with the court noting that upholding the rejection would have necessitated protracted adjudication and appeals, causing undue prejudice to the Petitioner.
HC allowed the writ, holding that rejection of the Petitioner's SVLDR-1 declaration without affording an opportunity of hearing violated principles of natural justice. The impugned e-mail rejection dated 6 February 2020 was quashed and set aside, and the declaration was ordered to be accepted with the duty liability quantified at Rs. 1,06,21,929/-. The Respondents were directed to compute the revised payable amount under the SVLDR scheme, deducting a verified pre-deposit of Rs. 29,72,500/-. The petition was disposed of, with the court noting that upholding the rejection would have necessitated protracted adjudication and appeals, causing undue prejudice to the Petitioner.
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