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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Belated statutory appeals under GST may still be entertained conditionally where the court exercises discretion despite expiry of limitation. The text explains that the writ challenge was not accepted on merits because the petitioner had not used the statutory reduced-penalty amnesty and had approached the court after the appeal period had lapsed. Even so, the court granted liberty to file an appeal within the time fixed, subject to pre-deposit of 25% of the disputed tax. On compliance, the appellate authority was directed to hear the appeal on merits, adjust any amount already recovered toward the pre-deposit, and lift bank attachment if applicable.
Belated statutory appeals under GST may still be entertained conditionally where the court exercises discretion despite expiry of limitation. The text explains that the writ challenge was not accepted on merits because the petitioner had not used the statutory reduced-penalty amnesty and had approached the court after the appeal period had lapsed. Even so, the court granted liberty to file an appeal within the time fixed, subject to pre-deposit of 25% of the disputed tax. On compliance, the appellate authority was directed to hear the appeal on merits, adjust any amount already recovered toward the pre-deposit, and lift bank attachment if applicable.
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