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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Interest for delayed payment of VAT on sales of ENA/RS/HBS was upheld on the basis that Rule 24(3) mandates tax payment through e-challan with the return, and Section 25(4) statutorily fastens interest when tax due is not paid within the prescribed time. Since the dealer filed (revised) returns showing "zero" tax despite collecting VAT and did not deposit the tax by the due date, the filing was treated as no return in the eyes of law, attracting interest for belated remittance. The plea of uncertainty regarding the applicable regime was rejected because VAT was payable at least at the applicable rate under Section 5(1)(e), and the petition challenging the levy of interest was dismissed. - HC
Interest for delayed payment of VAT on sales of ENA/RS/HBS was upheld on the basis that Rule 24(3) mandates tax payment through e-challan with the return, and Section 25(4) statutorily fastens interest when tax due is not paid within the prescribed time. Since the dealer filed (revised) returns showing "zero" tax despite collecting VAT and did not deposit the tax by the due date, the filing was treated as no return in the eyes of law, attracting interest for belated remittance. The plea of uncertainty regarding the applicable regime was rejected because VAT was payable at least at the applicable rate under Section 5(1)(e), and the petition challenging the levy of interest was dismissed. - HC
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