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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Delay and laches barred interference under Article 226 where the petitioner failed to respond properly to the discrepancy notice and show cause notice, did not furnish invoice details before the statutory authority, and raised supplier certificates only belatedly despite their earlier availability. The High Court found no justifiable basis to reopen an assessment that had already attained finality, particularly in view of the prolonged delay and the petitioner's negligence in the statutory proceedings. The writ petition was dismissed and the assessment order left undisturbed.
Delay and laches barred interference under Article 226 where the petitioner failed to respond properly to the discrepancy notice and show cause notice, did not furnish invoice details before the statutory authority, and raised supplier certificates only belatedly despite their earlier availability. The High Court found no justifiable basis to reopen an assessment that had already attained finality, particularly in view of the prolonged delay and the petitioner's negligence in the statutory proceedings. The writ petition was dismissed and the assessment order left undisturbed.
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