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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Application for rectification is confined to errors apparent on the record; re appreciation of evidence or revisiting factual findings is impermissible, and the rectification plea was dismissed. Penalty assessment principle confirmed: penalty must not exceed the demand upheld on remand, and Section 78 liability is to be re determined equal to the confirmed demand. Contract interpretation finding that the work order price expressly included service tax is a factual conclusion supported by contract terms and is not a patent error subject to rectification; that ground was rejected.
Application for rectification is confined to errors apparent on the record; re appreciation of evidence or revisiting factual findings is impermissible, and the rectification plea was dismissed. Penalty assessment principle confirmed: penalty must not exceed the demand upheld on remand, and Section 78 liability is to be re determined equal to the confirmed demand. Contract interpretation finding that the work order price expressly included service tax is a factual conclusion supported by contract terms and is not a patent error subject to rectification; that ground was rejected.
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