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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SC upheld the HC orders condoning delay in filing tax appeals by the Revenue but found the HC's reasoning deficient and insufficiently detailed; the SC held that the HC must examine the facts pleaded in applications for condonation of delay with particularity before final disposal. Although no serious procedural or substantive error warranted interference with the condonation orders, in the interest of justice the SC directed the Revenue to pay costs quantified at Rs.25,000 to the respondent/assessees in each tax appeal before the HC and admonished that future condonation applications be decided on a detailed, fact-sensitive rationale.
SC upheld the HC orders condoning delay in filing tax appeals by the Revenue but found the HC's reasoning deficient and insufficiently detailed; the SC held that the HC must examine the facts pleaded in applications for condonation of delay with particularity before final disposal. Although no serious procedural or substantive error warranted interference with the condonation orders, in the interest of justice the SC directed the Revenue to pay costs quantified at Rs.25,000 to the respondent/assessees in each tax appeal before the HC and admonished that future condonation applications be decided on a detailed, fact-sensitive rationale.
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