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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Availment of input tax credit based on invoices issued by non-existing dealers is unsustainable where the taxpayer failed to respond to antecedent show cause notices, with resulting assessments under the relevant provisions remaining operative and rectification applications rejected. Statements of e-way bills alone are inadequate to prove physical receipt of goods; documentary proof such as delivery challans and receipts is required, and reliance solely on e-way bill summaries will not substantiate input tax credit claims. Writ remedies are not maintainable where statutory remedy and proceedings under the assessment scheme are available.
Availment of input tax credit based on invoices issued by non-existing dealers is unsustainable where the taxpayer failed to respond to antecedent show cause notices, with resulting assessments under the relevant provisions remaining operative and rectification applications rejected. Statements of e-way bills alone are inadequate to prove physical receipt of goods; documentary proof such as delivery challans and receipts is required, and reliance solely on e-way bill summaries will not substantiate input tax credit claims. Writ remedies are not maintainable where statutory remedy and proceedings under the assessment scheme are available.
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