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 - substantial delay of 166 days before ITAT - The appellant argued that the delay in filing the appeal before the ITAT was due to the absence of real-time alerts for notices and orders on the e-filing portal. However, the High Court found no sufficient cause to condone the delay, considering the appellant's history of non-compliance and lack of participation in the assessment proceedings. The Court emphasized the importance of timely and active participation in legal proceedings, dismissing the appeal due to the appellant's lackadaisical approach and habitual defiance of law.
Condonation of delay - substantial delay of 166 days before ITAT - The appellant argued that the delay in filing the appeal before the ITAT was due to the absence of real-time alerts for notices and orders on the e-filing portal. However, the High Court found no sufficient cause to condone the delay, considering the appellant's history of non-compliance and lack of participation in the assessment proceedings. The Court emphasized the importance of timely and active participation in legal proceedings, dismissing the appeal due to the appellant's lackadaisical approach and habitual defiance of law.
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