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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Board circulars are binding on the Department; beneficial clarifications apply retrospectively while adverse clarifications operate prospectively, so clearances made under CBEC Circular No.924/2010 cannot be subjected to retrospective duty for the pre-15.05.2014 period and that demand is unsustainable. Extended limitation for post-15.05.2014 recovery requires fraud, suppression or wilful misstatement, which the Department failed to establish, rendering the post-15.05.2014 demand time barred. Consequential penalties under penalty provisions are set aside where the duty demand fails and no deliberate contumacious conduct is shown. Recovery under the statute for amounts collected is remanded only for limited verification and appropriation of any shortfall.
Board circulars are binding on the Department; beneficial clarifications apply retrospectively while adverse clarifications operate prospectively, so clearances made under CBEC Circular No.924/2010 cannot be subjected to retrospective duty for the pre-15.05.2014 period and that demand is unsustainable. Extended limitation for post-15.05.2014 recovery requires fraud, suppression or wilful misstatement, which the Department failed to establish, rendering the post-15.05.2014 demand time barred. Consequential penalties under penalty provisions are set aside where the duty demand fails and no deliberate contumacious conduct is shown. Recovery under the statute for amounts collected is remanded only for limited verification and appropriation of any shortfall.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
