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 writ petition filed by A against the revenue authorities, holding that disability pension received on premature retirement from the Army is exempt income and not chargeable to tax. The HC quashed the impugned order passed u/s 119(2)(b) rejecting condonation of delay in filing the revised return and belated refund claim. It held that the authority erred in mechanically relying on Circular No. 9/2015 without appreciating the undisputed exempt nature of the disability pension. The respondents were directed to refund the entire income tax recovered for the relevant assessment years with interest at 9% p.a. within three months, failing which enhanced interest at 18% p.a. shall apply.
HC allowed the writ petition filed by A against the revenue authorities, holding that disability pension received on premature retirement from the Army is exempt income and not chargeable to tax. The HC quashed the impugned order passed u/s 119(2)(b) rejecting condonation of delay in filing the revised return and belated refund claim. It held that the authority erred in mechanically relying on Circular No. 9/2015 without appreciating the undisputed exempt nature of the disability pension. The respondents were directed to refund the entire income tax recovered for the relevant assessment years with interest at 9% p.a. within three months, failing which enhanced interest at 18% p.a. shall apply.
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