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 directed immediate release of the ornaments and books of account seized during the 1994 search, finding that the petitioner had executed the required indemnity bond and filed affidavits and that the Joint Commissioner of Income Tax (Range 4(1), Ahmedabad) had confirmed no outstanding demand and that no assessment, penalty or prosecution proceedings are pending. The respondents were ordered to release the seized property forthwith and to file a compliance report before the HC within one week. The direction is final and operative, obligating revenue authorities to restore the petitioner's seized property absent any extant tax liability or ongoing proceedings.
The HC directed immediate release of the ornaments and books of account seized during the 1994 search, finding that the petitioner had executed the required indemnity bond and filed affidavits and that the Joint Commissioner of Income Tax (Range 4(1), Ahmedabad) had confirmed no outstanding demand and that no assessment, penalty or prosecution proceedings are pending. The respondents were ordered to release the seized property forthwith and to file a compliance report before the HC within one week. The direction is final and operative, obligating revenue authorities to restore the petitioner's seized property absent any extant tax liability or ongoing proceedings.
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