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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Assessment u/s 153A r.w.s. 153C - Block period - Period of limitation - Where two assessments may result, in the case of a searched entity and the related person, both emanating from the same search, but relating to two different sets of assessment years. This certainly cannot be the intention of the Legislature. In fact, the decisions of the Delhi High Court are dated 30.10.2015 and 17.08.2017 and this, perhaps, would have been the reason for insertion of the portion within parenthesis in Section 153C(1). That is, and in the interests of clarity, the block period as applicable to a noticee under Section 153C will be the same as the years constituting the block in the case of the noticee under Section 153A. The two periods are aligned. This issue is accordingly answered, adverse to the petitioner. - HC
Assessment u/s 153A r.w.s. 153C - Block period - Period of limitation - Where two assessments may result, in the case of a searched entity and the related person, both emanating from the same search, but relating to two different sets of assessment years. This certainly cannot be the intention of the Legislature. In fact, the decisions of the Delhi High Court are dated 30.10.2015 and 17.08.2017 and this, perhaps, would have been the reason for insertion of the portion within parenthesis in Section 153C(1). That is, and in the interests of clarity, the block period as applicable to a noticee under Section 153C will be the same as the years constituting the block in the case of the noticee under Section 153A. The two periods are aligned. This issue is accordingly answered, adverse to the petitioner. - HC
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