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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Completed auction sales of timber before 1 July 2017 remained governed by the contractual terms and the pre-GST tax regime. The High Court held that the sale was completed on the auction dates, so the purchaser's tax liability became fixed then under the accepted contract terms requiring payment of the sale price along with Forest Development Tax and Sales Tax in force at that time. The later GST regime did not substitute that liability, because the extended payment period did not postpone completion of sale and Section 64-A of the Sale of Goods Act was excluded by the contract's contrary intention. The purchaser was therefore bound to pay the balance amount, pre-GST taxes, and contractual interest; the petition was dismissed.
Completed auction sales of timber before 1 July 2017 remained governed by the contractual terms and the pre-GST tax regime. The High Court held that the sale was completed on the auction dates, so the purchaser's tax liability became fixed then under the accepted contract terms requiring payment of the sale price along with Forest Development Tax and Sales Tax in force at that time. The later GST regime did not substitute that liability, because the extended payment period did not postpone completion of sale and Section 64-A of the Sale of Goods Act was excluded by the contract's contrary intention. The purchaser was therefore bound to pay the balance amount, pre-GST taxes, and contractual interest; the petition was dismissed.
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