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 allowed the petitions, quashing and setting aside the Designated Authority's rejection of the petitioner's Form-1 declaration under the DTVSV Scheme, 2024. The Court held that the petitioner, a declarant assessee, had a valid appeal pending before the CIT(Appeals) as on the specified date (22.07.2024) for AY 2014-15, notwithstanding non-condonation of delay, and thus fell within the statutory definition of "appellant." Relying on precedent and the Scheme's FAQs, the HC found the rejection unlawful and directed the Designated Authority to process the declaration under the Scheme in accordance with its terms. The petitions were allowed and disposed of.
The HC allowed the petitions, quashing and setting aside the Designated Authority's rejection of the petitioner's Form-1 declaration under the DTVSV Scheme, 2024. The Court held that the petitioner, a declarant assessee, had a valid appeal pending before the CIT(Appeals) as on the specified date (22.07.2024) for AY 2014-15, notwithstanding non-condonation of delay, and thus fell within the statutory definition of "appellant." Relying on precedent and the Scheme's FAQs, the HC found the rejection unlawful and directed the Designated Authority to process the declaration under the Scheme in accordance with its terms. The petitions were allowed and disposed of.
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