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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Dominant issue: whether informant is entitled to a final or enhanced reward under the Guidelines for Grant of Rewards to Informants, 2007. Reasoning: Clause 15.1 authorizes an interim reward (Rs.100,000 already paid) and Clauses 2.1, 13.1-13.2 prescribe that a three-member Committee determine final quantum, including adjustments post-appeal; no Committee decision or reasoned order was placed on record. Outcome: respondents must have the prescribed Committee hear the informant and decide-either enhance the reward or confirm no further payment-by a reasoned order within six months. - HC
Dominant issue: whether informant is entitled to a final or enhanced reward under the Guidelines for Grant of Rewards to Informants, 2007. Reasoning: Clause 15.1 authorizes an interim reward (Rs.100,000 already paid) and Clauses 2.1, 13.1-13.2 prescribe that a three-member Committee determine final quantum, including adjustments post-appeal; no Committee decision or reasoned order was placed on record. Outcome: respondents must have the prescribed Committee hear the informant and decide-either enhance the reward or confirm no further payment-by a reasoned order within six months. - HC
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