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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Where a declarant under the SVLDRS had made a mandatory pre-deposit in a pending appeal and disclosed it in Form SVLDRS-1, the designated committee was required to give credit for such pre-deposit while determining "tax dues" and issuing Form SVLDRS-2/3. As the pre-deposit was ignored, the quantified amount in Form SVLDRS-3 was held legally unsustainable and liable to be set aside. Consequently, the impugned Form SVLDRS-3 was quashed, and the authority was directed to issue a revised Form SVLDRS-3 after adjusting the pre-deposit and to thereafter issue the discharge certificate in Form SVLDRS-4 within the stipulated time. - HC
Where a declarant under the SVLDRS had made a mandatory pre-deposit in a pending appeal and disclosed it in Form SVLDRS-1, the designated committee was required to give credit for such pre-deposit while determining "tax dues" and issuing Form SVLDRS-2/3. As the pre-deposit was ignored, the quantified amount in Form SVLDRS-3 was held legally unsustainable and liable to be set aside. Consequently, the impugned Form SVLDRS-3 was quashed, and the authority was directed to issue a revised Form SVLDRS-3 after adjusting the pre-deposit and to thereafter issue the discharge certificate in Form SVLDRS-4 within the stipulated time. - HC
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