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 upheld the municipal corporation's authority under Sections 244, 245 read with 386 MMC Act to levy and revise licence fees for sky-signs, hoardings and advertisements. It held such exactions are "fees", not "tax", form part of municipal funds under Section 82, and are constitutionally supported by Article 243X read with Entries 5 and 66, List II; deletion of Entry 55 and introduction of GST do not impliedly repeal these provisions. The increased rate of Rs. 222 per sq. ft. per annum, sanctioned by the general body with effect from 1 April 2013, was held valid and not an impermissible retrospective levy, nor shown to be unreasonable or disproportionate. All challenges by petitioner-advertisers were rejected and the petition dismissed.
HC upheld the municipal corporation's authority under Sections 244, 245 read with 386 MMC Act to levy and revise licence fees for sky-signs, hoardings and advertisements. It held such exactions are "fees", not "tax", form part of municipal funds under Section 82, and are constitutionally supported by Article 243X read with Entries 5 and 66, List II; deletion of Entry 55 and introduction of GST do not impliedly repeal these provisions. The increased rate of Rs. 222 per sq. ft. per annum, sanctioned by the general body with effect from 1 April 2013, was held valid and not an impermissible retrospective levy, nor shown to be unreasonable or disproportionate. All challenges by petitioner-advertisers were rejected and the petition dismissed.
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