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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Departmental monetary thresholds under the National Litigation Policy apply to each appeal separately; the term "case" is to be read as each appeal being an individual case, so values of distinct appeals arising from a composite tribunal order cannot be aggregated to meet the filing limit. The High Court applied the departmental instruction and held that only one appeal (C.E.A.No.18 of 2025) met the prescribed monetary limit; the remaining departmental appeals were held not maintainable and dismissed for failure to satisfy the threshold.
Departmental monetary thresholds under the National Litigation Policy apply to each appeal separately; the term "case" is to be read as each appeal being an individual case, so values of distinct appeals arising from a composite tribunal order cannot be aggregated to meet the filing limit. The High Court applied the departmental instruction and held that only one appeal (C.E.A.No.18 of 2025) met the prescribed monetary limit; the remaining departmental appeals were held not maintainable and dismissed for failure to satisfy the threshold.
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