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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Validity of Reopening of assessment u/s 147 - reason to believe - Reply of the assessee through reproduced but the contents thereof are not even referred or analyzed prima facie - The High Court observed that the Assessing Officer had not adequately considered the evidence presented by the petitioner in response to the notice. According to Section 148A(d) of the Income Tax Act, the Assessing Officer is required to decide the validity of issuing a notice based on the material available, including the assessee's reply. However, in this case, the Assessing Officer's decision seemed to ignore the petitioner's evidence.
Validity of Reopening of assessment u/s 147 - reason to believe - Reply of the assessee through reproduced but the contents thereof are not even referred or analyzed prima facie - The High Court observed that the Assessing Officer had not adequately considered the evidence presented by the petitioner in response to the notice. According to Section 148A(d) of the Income Tax Act, the Assessing Officer is required to decide the validity of issuing a notice based on the material available, including the assessee's reply. However, in this case, the Assessing Officer's decision seemed to ignore the petitioner's evidence.
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