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 as infructuous the tax appeals, special civil applications and ancillary civil applications concerning provisional release of imported inshell walnuts and black pepper, where the respondent-assessee has since complied with the Department's conditions by furnishing bank guarantees in addition to the personal bond previously ordered by the Tribunal. Because the essential relief sought-release on execution of a provisional duty bond/surety instead of a bond with security/bank guarantee-has been rendered academic by the subsequent provision of the required bank guarantees and personal bond, the applications are disposed of as having ceased to present a live controversy and are therefore dismissed.
The HC dismissed as infructuous the tax appeals, special civil applications and ancillary civil applications concerning provisional release of imported inshell walnuts and black pepper, where the respondent-assessee has since complied with the Department's conditions by furnishing bank guarantees in addition to the personal bond previously ordered by the Tribunal. Because the essential relief sought-release on execution of a provisional duty bond/surety instead of a bond with security/bank guarantee-has been rendered academic by the subsequent provision of the required bank guarantees and personal bond, the applications are disposed of as having ceased to present a live controversy and are therefore dismissed.
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