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 held that, in the peculiar facts, the petitioner had diligently pursued its claim for interest on delayed IGST refund before appellate authorities under the Customs Act, and the jurisdictional objection was raised for the first time in the impugned order. HC permitted the petitioner to file an appeal against the common order dated 01.12.2020, limited to the issue of interest on IGST refunds, before the appellate authority under the GST Act within four weeks. HC directed that, if so filed, the appeal be decided on merits in accordance with law, without examining limitation. Appeal disposed.
HC held that, in the peculiar facts, the petitioner had diligently pursued its claim for interest on delayed IGST refund before appellate authorities under the Customs Act, and the jurisdictional objection was raised for the first time in the impugned order. HC permitted the petitioner to file an appeal against the common order dated 01.12.2020, limited to the issue of interest on IGST refunds, before the appellate authority under the GST Act within four weeks. HC directed that, if so filed, the appeal be decided on merits in accordance with law, without examining limitation. Appeal disposed.
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