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 petition and held that redemption fines imposed under the Central Excise regime are consequential to non-payment of duty and not a distinct category of penalty outside the ambit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDR Scheme). The Court concluded that payment under Section 124 of the SVLDR Scheme, and issuance of the discharge certificate, extinguishes the duty, interest and penalties, and therefore operates to waive redemption fines arising from seizure/confiscation. The Court directed that taxpayers who avail scheme benefits and pay the specified amount are entitled to waiver of redemption fines, extending the Scheme's finality to seizure/confiscation matters.
HC allowed the petition and held that redemption fines imposed under the Central Excise regime are consequential to non-payment of duty and not a distinct category of penalty outside the ambit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDR Scheme). The Court concluded that payment under Section 124 of the SVLDR Scheme, and issuance of the discharge certificate, extinguishes the duty, interest and penalties, and therefore operates to waive redemption fines arising from seizure/confiscation. The Court directed that taxpayers who avail scheme benefits and pay the specified amount are entitled to waiver of redemption fines, extending the Scheme's finality to seizure/confiscation matters.
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