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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Reassessment u/s 147 - admission of grounds of appeal of the Assessee under Rule 27 of the ITAT Rules - an Assessee may not have appealed or filed a cross-objection but he is free to defend such order on all grounds including on any of the grounds decided against him by the authority whose order is otherwise in his favour
Reassessment u/s 147 - admission of grounds of appeal of the Assessee under Rule 27 of the ITAT Rules - an Assessee may not have appealed or filed a cross-objection but he is free to defend such order on all grounds including on any of the grounds decided against him by the authority whose order is otherwise in his favour
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