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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The High Court noted that the appellate authority could not condone delay beyond the statutory period and upheld the rejection of the appeal on limitation. It nevertheless accepted that the taxpayer had bona fide reasons for not filing returns and that continued cancellation of GST registration would cause adverse civil consequences without benefiting revenue if compliance could still be secured. Exercising writ jurisdiction, the Court quashed the cancellation and appellate orders, directed restoration of registration, and allowed time to complete the remaining statutory obligations.
The High Court noted that the appellate authority could not condone delay beyond the statutory period and upheld the rejection of the appeal on limitation. It nevertheless accepted that the taxpayer had bona fide reasons for not filing returns and that continued cancellation of GST registration would cause adverse civil consequences without benefiting revenue if compliance could still be secured. Exercising writ jurisdiction, the Court quashed the cancellation and appellate orders, directed restoration of registration, and allowed time to complete the remaining statutory obligations.
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