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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Reopening of assessment u/s 147 - Non speaking order disposing of objections against reopening - Disposal of this matter is needed as dealing with the objections to the reasons recorded is not a static formality to be undergone to rush to the forming of assessment. Even while accepting the requirements of a focus on substantive justice in the process, it is a vital step towards that and hence mandate in GKN Driveshafts (INDIA) Ltd. (supra) must not be undermined, nor can that be diluted. - Without setting aside the notice, assessment order quashed - HC
Reopening of assessment u/s 147 - Non speaking order disposing of objections against reopening - Disposal of this matter is needed as dealing with the objections to the reasons recorded is not a static formality to be undergone to rush to the forming of assessment. Even while accepting the requirements of a focus on substantive justice in the process, it is a vital step towards that and hence mandate in GKN Driveshafts (INDIA) Ltd. (supra) must not be undermined, nor can that be diluted. - Without setting aside the notice, assessment order quashed - HC
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