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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Condonation of delay - Delay in filling of an appeal before ITAT - The ITAT observed taht the appeal was delayed by 17 days. The assessee claimed the delay was due to illness, but failed to provide sufficient evidence to support this claim. The lack of participation and cooperation by the assessee throughout the assessment process further weakened their case for condonation of the delay. Considering the lack of a convincing explanation for the delay and the assessee's history of non-cooperation, the ITAT upheld the dismissal of the appeal by the Commissioner of Income-Tax (Appeals) due to non-prosecution.
Condonation of delay - Delay in filling of an appeal before ITAT - The ITAT observed taht the appeal was delayed by 17 days. The assessee claimed the delay was due to illness, but failed to provide sufficient evidence to support this claim. The lack of participation and cooperation by the assessee throughout the assessment process further weakened their case for condonation of the delay. Considering the lack of a convincing explanation for the delay and the assessee's history of non-cooperation, the ITAT upheld the dismissal of the appeal by the Commissioner of Income-Tax (Appeals) due to non-prosecution.
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