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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Profiteering analysis found a residual input-tax-credit benefit of Rs.5,80,280 due to 13 eligible home buyers in a residential project; respondent already passed greater ITC benefit to 240 buyers. Tribunal directs the respondent to pay the balance Rs.5,80,280 to the 13 buyers with interest as per Rule 133(3)(b) within 30 days and to file a compliance report with the CGST/SGST Commissioner and DGAP within two months. Penalty under Section 171(3A) is held leviable because the contravention period extends into the provision's operative date (01.01.2020).
Profiteering analysis found a residual input-tax-credit benefit of Rs.5,80,280 due to 13 eligible home buyers in a residential project; respondent already passed greater ITC benefit to 240 buyers. Tribunal directs the respondent to pay the balance Rs.5,80,280 to the 13 buyers with interest as per Rule 133(3)(b) within 30 days and to file a compliance report with the CGST/SGST Commissioner and DGAP within two months. Penalty under Section 171(3A) is held leviable because the contravention period extends into the provision's operative date (01.01.2020).
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