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 in filing of revised return of income - CBDT rejecting petitioner’s application u/s 119 - Acceptance of Recast Financials - The High Court criticized the CBDT for its refusal to accept the recast financial statements, noting that the non-acceptance was contrary to the principles of genuine hardship. The court highlighted that the petitioner's hardships were genuine and disregarded by the CBDT without substantial justification. - The court affirmed that the recasting of books under the Companies Act, mandated by the NCLT, should influence tax proceedings, contradicting the CBDT's stance that these are separate realms. - The HC directed the tax authorities to allow the filing of revised returns based on the recast financial statements and proceed accordingly.
Condonation of delay in filing of revised return of income - CBDT rejecting petitioner’s application u/s 119 - Acceptance of Recast Financials - The High Court criticized the CBDT for its refusal to accept the recast financial statements, noting that the non-acceptance was contrary to the principles of genuine hardship. The court highlighted that the petitioner's hardships were genuine and disregarded by the CBDT without substantial justification. - The court affirmed that the recasting of books under the Companies Act, mandated by the NCLT, should influence tax proceedings, contradicting the CBDT's stance that these are separate realms. - The HC directed the tax authorities to allow the filing of revised returns based on the recast financial statements and proceed accordingly.
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