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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Addition of excess jewellery found in search - The Court interpreted CBDT Instruction 1916 and emphasized that it pertains to the seizure stage and does not dictate assessment procedures. It allows discretion to exclude larger quantities of jewellery from seizure based on factors like family status and community customs. Since the circular is applicable only during the seizure stage, the Court ruled that the respondent's failure to follow it during assessment does not warrant interference. The Court reminded the petitioner of the availability of an alternate remedy before the Appellate Commissioner u/s 246A of the Income Tax Act.
Addition of excess jewellery found in search - The Court interpreted CBDT Instruction 1916 and emphasized that it pertains to the seizure stage and does not dictate assessment procedures. It allows discretion to exclude larger quantities of jewellery from seizure based on factors like family status and community customs. Since the circular is applicable only during the seizure stage, the Court ruled that the respondent's failure to follow it during assessment does not warrant interference. The Court reminded the petitioner of the availability of an alternate remedy before the Appellate Commissioner u/s 246A of the Income Tax Act.
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