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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Validity of electronic service was upheld: service of notice and relied upon documents by email/PDF complied with the Adjudicating Authority (Procedure) Regulations, 2013 read with the Information Technology Act and was valid in the HC. The Adjudicating Authority's recorded reasons to believe in the show cause notice were legally sufficient, articulating a prima facie basis and reserving final view; no illegality was found. The completeness of relied upon documents was remitted to the Adjudicating Authority, which must determine whether additional RUDs exist, direct their supply within two weeks if so, and permit a two week supplementary reply thereafter.
Validity of electronic service was upheld: service of notice and relied upon documents by email/PDF complied with the Adjudicating Authority (Procedure) Regulations, 2013 read with the Information Technology Act and was valid in the HC. The Adjudicating Authority's recorded reasons to believe in the show cause notice were legally sufficient, articulating a prima facie basis and reserving final view; no illegality was found. The completeness of relied upon documents was remitted to the Adjudicating Authority, which must determine whether additional RUDs exist, direct their supply within two weeks if so, and permit a two week supplementary reply thereafter.
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