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 Ex-parte assessment order passed u/s 144B - The High Court acknowledged the petitioner's arguments and found gross violations of essential principles of natural justice by the assessing authority. It noted that no real opportunity of hearing was granted to the petitioner, and the order was passed without conducting any proceedings involving them. Therefore, the Court set aside the assessment order. - The Court directed the petitioner to treat the order as a final show-cause notice and submit their reply within one week. If the Assessing Officer accepts the petitioner's explanation, the consequential order may be passed without fixing any further date for hearing.
Validity of Ex-parte assessment order passed u/s 144B - The High Court acknowledged the petitioner's arguments and found gross violations of essential principles of natural justice by the assessing authority. It noted that no real opportunity of hearing was granted to the petitioner, and the order was passed without conducting any proceedings involving them. Therefore, the Court set aside the assessment order. - The Court directed the petitioner to treat the order as a final show-cause notice and submit their reply within one week. If the Assessing Officer accepts the petitioner's explanation, the consequential order may be passed without fixing any further date for hearing.
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