Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Revision u/s 263 - debatable issue - taxability of interest received by the Assessee on the enhanced compensation u/s 28 of the Land Acquisition Act - The Appellate Tribunal examined the issues raised and found that the initiation of proceedings under section 263 lacked merit, as the order passed under section 154 of the Act rectifying the mistake apparent from the record was valid. Moreover, the Tribunal recognized the debatable nature of the taxability issue and emphasized that when two plausible views exist, the jurisdictional PCIT cannot assume jurisdiction under section 263 of the Act.
Revision u/s 263 - debatable issue - taxability of interest received by the Assessee on the enhanced compensation u/s 28 of the Land Acquisition Act - The Appellate Tribunal examined the issues raised and found that the initiation of proceedings under section 263 lacked merit, as the order passed under section 154 of the Act rectifying the mistake apparent from the record was valid. Moreover, the Tribunal recognized the debatable nature of the taxability issue and emphasized that when two plausible views exist, the jurisdictional PCIT cannot assume jurisdiction under section 263 of the Act.
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