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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Extended limitation period cannot be invoked where there is no proof of suppression or malafide: contemporaneous documentary records and communications from SEZ/FTWZ authorities negated concealment and showed accepted administrative practice, so absence of an undertaking did not amount to deliberate misdeclaration. Consequently, demands for the disputed periods were time barred and the adjudication invoking extended limitation set aside. Coordinate Tribunal precedents addressing SAD exemption on SEZ/FTWZ to DTA transfers - with higher court leave to appeal or SLPs dismissed - compelled the same result, so the appeals were allowed on limitation grounds without adjudicating substantive entitlement to Special Additional Duty exemption.
Extended limitation period cannot be invoked where there is no proof of suppression or malafide: contemporaneous documentary records and communications from SEZ/FTWZ authorities negated concealment and showed accepted administrative practice, so absence of an undertaking did not amount to deliberate misdeclaration. Consequently, demands for the disputed periods were time barred and the adjudication invoking extended limitation set aside. Coordinate Tribunal precedents addressing SAD exemption on SEZ/FTWZ to DTA transfers - with higher court leave to appeal or SLPs dismissed - compelled the same result, so the appeals were allowed on limitation grounds without adjudicating substantive entitlement to Special Additional Duty exemption.
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