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 set aside the rejection of refund of unutilized input tax credit on export of services under Section 54 CGST Act read with Rule 89 CGST Rules. The authorities had denied refund on the ground that the exporter furnished FIRAs and a Chartered Accountant's certificate instead of FIRCs as required under a CBIC circular. Relying on its earlier decision in the same assessee's case, HC held that receipt of convertible foreign exchange was established and mere non-furnishing of FIRCs could not justify rejection of refund. Authorities were directed to process the refund claims for the specified tax periods within twelve weeks.
HC set aside the rejection of refund of unutilized input tax credit on export of services under Section 54 CGST Act read with Rule 89 CGST Rules. The authorities had denied refund on the ground that the exporter furnished FIRAs and a Chartered Accountant's certificate instead of FIRCs as required under a CBIC circular. Relying on its earlier decision in the same assessee's case, HC held that receipt of convertible foreign exchange was established and mere non-furnishing of FIRCs could not justify rejection of refund. Authorities were directed to process the refund claims for the specified tax periods within twelve weeks.
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