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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Legality and validity of the order of attaching the bank account of the writ-applicant in exercise of power u/s 44 of the GVAT Act - he plain reading of the aforesaid communication would indicate that the matter was closed for the assessment year 2010-11 - as the condition precedent for invoking Section 34(8A) of the Act is not fulfilled in the present case, not only the impugned order dated 08.07.2019 of assessment is rendered illegal, but even the subsequent action in the form of attachment order under Section 44 of the Act would be rendered without jurisdiction. - HC
Legality and validity of the order of attaching the bank account of the writ-applicant in exercise of power u/s 44 of the GVAT Act - he plain reading of the aforesaid communication would indicate that the matter was closed for the assessment year 2010-11 - as the condition precedent for invoking Section 34(8A) of the Act is not fulfilled in the present case, not only the impugned order dated 08.07.2019 of assessment is rendered illegal, but even the subsequent action in the form of attachment order under Section 44 of the Act would be rendered without jurisdiction. - HC
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