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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Where a declarant furnished details under the Voluntary Compliance Encouragement Scheme (VCES) and received an acknowledgement of discharge, the scheme grants immunity from penalty, interest and further proceedings in respect of the declared tax dues; consequently, any subsequent notice or recovery proceeding that seeks to assess or recover an identical liability or that overlaps even slightly with dues already discharged under VCES is barred. Applying the conclusive effect of the VCES acknowledgement, the impugned demand was set aside insofar as it sought recovery of tax already verified and settled under the scheme, entitling the declarant to consequential relief.
Where a declarant furnished details under the Voluntary Compliance Encouragement Scheme (VCES) and received an acknowledgement of discharge, the scheme grants immunity from penalty, interest and further proceedings in respect of the declared tax dues; consequently, any subsequent notice or recovery proceeding that seeks to assess or recover an identical liability or that overlaps even slightly with dues already discharged under VCES is barred. Applying the conclusive effect of the VCES acknowledgement, the impugned demand was set aside insofar as it sought recovery of tax already verified and settled under the scheme, entitling the declarant to consequential relief.
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