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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Appellate authority lacked power to condone delay beyond the statutory 90-day limitation, so its dismissal on an 88-day delay was technically proper. The High Court, exercising writ jurisdiction under Article 226, may condone delay if reasons are stated in the memo of appeal; on the facts hospitalisation of the appellant's mother for cancer and a bona fide deposit (7.5%) towards filing the High Court exercised that power and set aside the impugned order, with stay operating in favour of the appellant since 06.02.2017.
Appellate authority lacked power to condone delay beyond the statutory 90-day limitation, so its dismissal on an 88-day delay was technically proper. The High Court, exercising writ jurisdiction under Article 226, may condone delay if reasons are stated in the memo of appeal; on the facts hospitalisation of the appellant's mother for cancer and a bona fide deposit (7.5%) towards filing the High Court exercised that power and set aside the impugned order, with stay operating in favour of the appellant since 06.02.2017.
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