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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Revision u/s 263 by CIT - the ITAT upheld the impugned order, dismissing the appeal of the assessee. The Tribunal ruled that the CIT had exercised revisional jurisdiction after independently examining the records and applying their mind to the case. Additionally, they found that the reference made by the Assessing Officer to the TPO was invalid due to the expiration of the time limit, making it no reference in the eyes of the law.
Revision u/s 263 by CIT - the ITAT upheld the impugned order, dismissing the appeal of the assessee. The Tribunal ruled that the CIT had exercised revisional jurisdiction after independently examining the records and applying their mind to the case. Additionally, they found that the reference made by the Assessing Officer to the TPO was invalid due to the expiration of the time limit, making it no reference in the eyes of the law.
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