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 held that the Designated Authority erred in rejecting the petitioner's Form-1 declaration under the DTVSV Scheme, 2024 solely because the related appeal was later held non-maintainable; on the specified date (22.07.2024) the appeal was pending and therefore the declaration could not be rejected as not valid or competent. The court quashed and set aside the impugned communication dated 11.04.2025 and directed the Designated Authority to process the petitioner's Form-1 declaration in accordance with the Scheme, observing that a subsequent finding of non-maintainability does not negate the appeal's pending status on the material date.
The HC held that the Designated Authority erred in rejecting the petitioner's Form-1 declaration under the DTVSV Scheme, 2024 solely because the related appeal was later held non-maintainable; on the specified date (22.07.2024) the appeal was pending and therefore the declaration could not be rejected as not valid or competent. The court quashed and set aside the impugned communication dated 11.04.2025 and directed the Designated Authority to process the petitioner's Form-1 declaration in accordance with the Scheme, observing that a subsequent finding of non-maintainability does not negate the appeal's pending status on the material date.
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