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 service tax liability was admitted and quantified during investigation prior to the SVLDRS cut-off date of 30.06.2019, the authority could not reject the declarant's SVLDRS Form-1 on the ground that the return was filed belatedly or due to a discrepancy between the quantified amount and the figure stated in Form-1. Quantification before the cut-off satisfied the scheme's eligibility requirement, and denial on that basis was erroneous. The rejection endorsement was quashed, and the authority was directed to issue SVLDRS Form-II, enabling further processing under the scheme; the petition was allowed - HC
Where service tax liability was admitted and quantified during investigation prior to the SVLDRS cut-off date of 30.06.2019, the authority could not reject the declarant's SVLDRS Form-1 on the ground that the return was filed belatedly or due to a discrepancy between the quantified amount and the figure stated in Form-1. Quantification before the cut-off satisfied the scheme's eligibility requirement, and denial on that basis was erroneous. The rejection endorsement was quashed, and the authority was directed to issue SVLDRS Form-II, enabling further processing under the scheme; the petition was allowed - HC
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