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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Validity of special audit u/s 142(2A) - The Jharkhand High Court upheld the orders for a special audit of the petitioner’s accounts for the assessment years 2020-21 and 2022-23. The court found that the discrepancies in the petitioner’s accounts justified the special audit and that the statutory requirements for ordering such an audit were met. While the court acknowledged a procedural lapse in providing insufficient time for the petitioner to respond, it held that this did not cause significant prejudice to warrant interference. The petitioner’s writ petitions were dismissed, with the court providing additional time for the audit and specific directions to ensure a fair audit process.
Validity of special audit u/s 142(2A) - The Jharkhand High Court upheld the orders for a special audit of the petitioner’s accounts for the assessment years 2020-21 and 2022-23. The court found that the discrepancies in the petitioner’s accounts justified the special audit and that the statutory requirements for ordering such an audit were met. While the court acknowledged a procedural lapse in providing insufficient time for the petitioner to respond, it held that this did not cause significant prejudice to warrant interference. The petitioner’s writ petitions were dismissed, with the court providing additional time for the audit and specific directions to ensure a fair audit process.
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