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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Assessment completed u/s 144C against a petitioner/Non-Resident Indian - The High Court held that Section 144C is a procedural provision introduced for the benefit of assesses, including NRIs, effective from April 1, 2020. The petitioner's objection to being assessed under Section 144C was deemed meritless as the provision is beneficial and procedural, not substantive. The Court emphasized that the petitioner failed to raise this objection before the assessing authority, rendering it invalid. - Further on the issue of limitation: The High Court noted the provided timeline demonstrated compliance with statutory procedures and extensions granted under TOLA. It concluded that the assessment order was passed within the prescribed time limit, as per the provisions of Section 144C, rendering the petitioner's objection baseless.
Assessment completed u/s 144C against a petitioner/Non-Resident Indian - The High Court held that Section 144C is a procedural provision introduced for the benefit of assesses, including NRIs, effective from April 1, 2020. The petitioner's objection to being assessed under Section 144C was deemed meritless as the provision is beneficial and procedural, not substantive. The Court emphasized that the petitioner failed to raise this objection before the assessing authority, rendering it invalid. - Further on the issue of limitation: The High Court noted the provided timeline demonstrated compliance with statutory procedures and extensions granted under TOLA. It concluded that the assessment order was passed within the prescribed time limit, as per the provisions of Section 144C, rendering the petitioner's objection baseless.
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