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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Suppression of facts and non cooperation during audit established intent to evade service tax, justifying invocation of the proviso to Section 73(1) to extend limitation; consequence: extended-period demand sustained. Taxable value for residential construction was determined using Notification No.26/2012 ST with prescribed abatement applied, excluding verifiable sale of plot amounts; consequence: valuation and tax demand upheld. Penalties and interest for non payment and default were held justified, and officer/agent/director liability under the relevant liability provision was affirmed though individual appellants who did not appeal were not considered. Revenue's alternate site formation tax claim lacked substantiation and failed.
Suppression of facts and non cooperation during audit established intent to evade service tax, justifying invocation of the proviso to Section 73(1) to extend limitation; consequence: extended-period demand sustained. Taxable value for residential construction was determined using Notification No.26/2012 ST with prescribed abatement applied, excluding verifiable sale of plot amounts; consequence: valuation and tax demand upheld. Penalties and interest for non payment and default were held justified, and officer/agent/director liability under the relevant liability provision was affirmed though individual appellants who did not appeal were not considered. Revenue's alternate site formation tax claim lacked substantiation and failed.
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