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 Faceless assessment of income escaping assessment u/s 151 - According to Petitioners, the notice could have been issued only by the Faceless Assessing Officer (“FAO”) not issued by the Jurisdictional Assessing Officer (“JAO”) - The court acknowledged that the issues in the present petitions were covered by the Hexaware Technologies judgment and consequently quashed the impugned notices. Any reassessment orders, demand notices, or penalties based on these invalid notices were also set aside. The court extended this benefit to petitioners who had raised the issue of notice validity orally and disposed of the petitions and any pending interim applications accordingly.
Validity of Faceless assessment of income escaping assessment u/s 151 - According to Petitioners, the notice could have been issued only by the Faceless Assessing Officer (“FAO”) not issued by the Jurisdictional Assessing Officer (“JAO”) - The court acknowledged that the issues in the present petitions were covered by the Hexaware Technologies judgment and consequently quashed the impugned notices. Any reassessment orders, demand notices, or penalties based on these invalid notices were also set aside. The court extended this benefit to petitioners who had raised the issue of notice validity orally and disposed of the petitions and any pending interim applications accordingly.
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