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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Special audit u/s 142(2A) - Complexity and Volume of Transactions - Reasonable Opportunity to be Heard - Despite recognizing a breach of natural justice due to the insufficient response time, the High Court ruled that this breach did not cause substantial prejudice to the petitioner. The court emphasized the importance of a prima facie assessment for special audits and supported the Assessing Officer's discretion in such matters. Consequently, the court extended the audit report submission deadline and limited the audit scope, ensuring the petitioner's rights were protected while upholding the Revenue's interests.
Special audit u/s 142(2A) - Complexity and Volume of Transactions - Reasonable Opportunity to be Heard - Despite recognizing a breach of natural justice due to the insufficient response time, the High Court ruled that this breach did not cause substantial prejudice to the petitioner. The court emphasized the importance of a prima facie assessment for special audits and supported the Assessing Officer's discretion in such matters. Consequently, the court extended the audit report submission deadline and limited the audit scope, ensuring the petitioner's rights were protected while upholding the Revenue's interests.
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