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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Levy of interest for delayed discharge of tax liability was imposed after the taxpayer failed to reply to a show cause notice in Form GST DRC-01, and the demand was confirmed under the assessment procedure in Section 73. Interest was levied under Section 50(1) on the basis of delayed payment, and the challenge to that levy lacked merit. The writ petition challenging the demand and interest was held not maintainable and dismissed, with the consequence that the confirmed tax demand and interest remain enforceable.
Levy of interest for delayed discharge of tax liability was imposed after the taxpayer failed to reply to a show cause notice in Form GST DRC-01, and the demand was confirmed under the assessment procedure in Section 73. Interest was levied under Section 50(1) on the basis of delayed payment, and the challenge to that levy lacked merit. The writ petition challenging the demand and interest was held not maintainable and dismissed, with the consequence that the confirmed tax demand and interest remain enforceable.
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