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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Violation of principles of natural justice - duplication of ITC - The petitioner contended that their detailed reply addressing each allegation with supporting documents was not adequately considered by the tax authority. The Court found the tax authority's rejection of the petitioner's reply solely on grounds of incompleteness unsustainable, emphasizing the necessity for proper consideration of the documents and explanations provided. It directed the remittance of the matter for re-adjudication, granting the petitioner an opportunity to file a further reply and directing the Proper Officer to examine the contention regarding the reversal of erroneously availed ITC.
Violation of principles of natural justice - duplication of ITC - The petitioner contended that their detailed reply addressing each allegation with supporting documents was not adequately considered by the tax authority. The Court found the tax authority's rejection of the petitioner's reply solely on grounds of incompleteness unsustainable, emphasizing the necessity for proper consideration of the documents and explanations provided. It directed the remittance of the matter for re-adjudication, granting the petitioner an opportunity to file a further reply and directing the Proper Officer to examine the contention regarding the reversal of erroneously availed ITC.
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