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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Seeking directions to de-freeze the bank accounts - The court carefully examined the relevant provisions of the Income Tax Act and found that the freezing of bank accounts cannot extend beyond sixty days from the date of the order. Despite being given opportunities to justify their actions, the respondents failed to provide sufficient reasons for the continued freeze. Therefore, the court declared the letter freezing the accounts unenforceable beyond the sixty-day period and directed the immediate defreezing of the accounts.
Seeking directions to de-freeze the bank accounts - The court carefully examined the relevant provisions of the Income Tax Act and found that the freezing of bank accounts cannot extend beyond sixty days from the date of the order. Despite being given opportunities to justify their actions, the respondents failed to provide sufficient reasons for the continued freeze. Therefore, the court declared the letter freezing the accounts unenforceable beyond the sixty-day period and directed the immediate defreezing of the accounts.
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