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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Levy of penalty u/s 271D V/S 271E - alleged violation of section 269SS having received Rs.15.50 lacs, in cash from wife - allegation of default specified u/s. 269-T - wrong mention of a section (provision of law) - the penalty u/s. 271D, though not time barred, is not maintainable in the absence of the necessary jurisdiction - the penalty levied is for the default specified u/s. 269-T, and though merited on the whole sum and, in any case, part thereof, is not sustainable in the absence of any penalty having been initiated or levied u/s. 271-E - AT
Levy of penalty u/s 271D V/S 271E - alleged violation of section 269SS having received Rs.15.50 lacs, in cash from wife - allegation of default specified u/s. 269-T - wrong mention of a section (provision of law) - the penalty u/s. 271D, though not time barred, is not maintainable in the absence of the necessary jurisdiction - the penalty levied is for the default specified u/s. 269-T, and though merited on the whole sum and, in any case, part thereof, is not sustainable in the absence of any penalty having been initiated or levied u/s. 271-E - AT
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