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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Violation of principles of natural justice - It was contended that impugned order does not take into consideration the reply submitted by the Petitioner and is a cryptic order - The High Court found that the impugned order failed to properly consider the petitioner's detailed reply. Instead, it merely stated that the reply was unsatisfactory without providing specific reasons or engaging with the content of the response. This lack of substantive consideration indicated that the Proper Officer did not apply their mind to the petitioner's submission. - Matter restored back for reconsideration.
Violation of principles of natural justice - It was contended that impugned order does not take into consideration the reply submitted by the Petitioner and is a cryptic order - The High Court found that the impugned order failed to properly consider the petitioner's detailed reply. Instead, it merely stated that the reply was unsatisfactory without providing specific reasons or engaging with the content of the response. This lack of substantive consideration indicated that the Proper Officer did not apply their mind to the petitioner's submission. - Matter restored back for reconsideration.
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