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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Revision u/s 263 - as argued no draft assessment order u/s 144C prior to passing the final assessment order passed - The Tribunal analyzed the circulars cited by the PCIT and concluded that they were explanatory in nature and did not invoke the powers of Section 119 of the Act. As such, non-compliance with these circulars did not render the assessment order erroneous. Moreover, the Tribunal cited precedents to establish that a non-est and void order cannot be subject to revisionary proceedings under Section 263. Therefore, the exercise of jurisdiction by invoking clause (c) of Explanation 2 of Section 263(1) of the Act was deemed inappropriate.
Revision u/s 263 - as argued no draft assessment order u/s 144C prior to passing the final assessment order passed - The Tribunal analyzed the circulars cited by the PCIT and concluded that they were explanatory in nature and did not invoke the powers of Section 119 of the Act. As such, non-compliance with these circulars did not render the assessment order erroneous. Moreover, the Tribunal cited precedents to establish that a non-est and void order cannot be subject to revisionary proceedings under Section 263. Therefore, the exercise of jurisdiction by invoking clause (c) of Explanation 2 of Section 263(1) of the Act was deemed inappropriate.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
