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 quashed the impugned SVLDRS-3 to the extent it directed the anonymized petitioner to pay Rs.1,12,65,902/-, holding that the authorities failed to examine and verify challans and payments produced by the petitioner within the timelines and the respondents' own show-cause process. The SVLDRS-3 determination is set aside, and the matter is remitted for de novo verification by the designated committee of the petitioner's claims regarding pre-deposits and amounts recovered during investigations; if verification under Section 124(2) establishes entitlement, such amounts must be adjusted in computing liability under the scheme. Petition allowed.
The HC quashed the impugned SVLDRS-3 to the extent it directed the anonymized petitioner to pay Rs.1,12,65,902/-, holding that the authorities failed to examine and verify challans and payments produced by the petitioner within the timelines and the respondents' own show-cause process. The SVLDRS-3 determination is set aside, and the matter is remitted for de novo verification by the designated committee of the petitioner's claims regarding pre-deposits and amounts recovered during investigations; if verification under Section 124(2) establishes entitlement, such amounts must be adjusted in computing liability under the scheme. Petition allowed.
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