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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Refusal to grant certified copies of the order sheet/note sheet and search warrant - The High Court concluded that the petitioner's request for certified copies was not justified at this stage of the investigation. - It clarified that the investigation process is not complete upon the issuance of an SCN, and a final decision is reached after the matter goes through all stages of appeals and revisions. - The Court noted that disclosing information from order sheets could reveal the identity of sources and jeopardize ongoing investigations. - Petition dismissed.
Refusal to grant certified copies of the order sheet/note sheet and search warrant - The High Court concluded that the petitioner's request for certified copies was not justified at this stage of the investigation. - It clarified that the investigation process is not complete upon the issuance of an SCN, and a final decision is reached after the matter goes through all stages of appeals and revisions. - The Court noted that disclosing information from order sheets could reveal the identity of sources and jeopardize ongoing investigations. - Petition dismissed.
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