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 the writ petitions and upheld the constitutional validity of the proviso to s.194A(3) of the Income-tax Act as amended by the Finance Act, 2020. The court held that a proviso may operate substantively to alter a principal provision where legislative intent so indicates, and that the proviso here legitimately conditions the non-applicability of s.194A(1) on the payer's turnover/gross receipts without manifest arbitrariness or breach of legislative competence or fundamental rights. The petitioners, being primary agricultural credit societies not conducting banking as defined under the Banking Regulation Act, failed to establish entitlement to relief under s.194A(3)(iii). Accordingly, no interference was warranted.
The HC dismissed the writ petitions and upheld the constitutional validity of the proviso to s.194A(3) of the Income-tax Act as amended by the Finance Act, 2020. The court held that a proviso may operate substantively to alter a principal provision where legislative intent so indicates, and that the proviso here legitimately conditions the non-applicability of s.194A(1) on the payer's turnover/gross receipts without manifest arbitrariness or breach of legislative competence or fundamental rights. The petitioners, being primary agricultural credit societies not conducting banking as defined under the Banking Regulation Act, failed to establish entitlement to relief under s.194A(3)(iii). Accordingly, no interference was warranted.
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