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 of income in the hands of the assessee - fraudulent filing of returns of income by the Chartered Accountant - The finding by the Board of Discipline of ICAI is to the effect that the said CA, with the connivance of the partners of the assessee, prepared fake documents to support the ITR which was uploaded without the knowledge of the assessee. It prima facie creates any doubt as to whether there is any income in the hands of the assessee for this year or not? - Since the criminal case is pending against the alleged perpetrators of the fraud, AO directed to take a view in view of the outcome of the criminal case - AT
Assessment of income in the hands of the assessee - fraudulent filing of returns of income by the Chartered Accountant - The finding by the Board of Discipline of ICAI is to the effect that the said CA, with the connivance of the partners of the assessee, prepared fake documents to support the ITR which was uploaded without the knowledge of the assessee. It prima facie creates any doubt as to whether there is any income in the hands of the assessee for this year or not? - Since the criminal case is pending against the alleged perpetrators of the fraud, AO directed to take a view in view of the outcome of the criminal case - AT
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