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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Rule 86A(2) empowers the Commissioner or authorised officer to permit debit of the electronic credit ledger once satisfied that the conditions justifying blockage under Rule 86A(1) no longer exist. Since the taxpayer had submitted a representation seeking unblocking and the authority had not taken any decision as mandated by Rule 86A(2), the court required administrative determination on that request. The authority was directed to pass a reasoned order on the taxpayer's representation within two weeks, and the writ petition was disposed of accordingly. - HC
Rule 86A(2) empowers the Commissioner or authorised officer to permit debit of the electronic credit ledger once satisfied that the conditions justifying blockage under Rule 86A(1) no longer exist. Since the taxpayer had submitted a representation seeking unblocking and the authority had not taken any decision as mandated by Rule 86A(2), the court required administrative determination on that request. The authority was directed to pass a reasoned order on the taxpayer's representation within two weeks, and the writ petition was disposed of accordingly. - HC
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