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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Revision u/s 263 - order framed u/s 153A - The Tribunal (ITAT) held that, the assessment orders approved u/s 153D cannot be revised u/s 263 without first revising the approval itself. The AO conducted adequate and reasonable enquiries, fulfilling the requirements of a proper assessment. - The Tribunal emphasized the legal principle that when two views are possible, the AO's decision to adopt one permissible view cannot be deemed erroneous or prejudicial to the interests of the revenue.
Revision u/s 263 - order framed u/s 153A - The Tribunal (ITAT) held that, the assessment orders approved u/s 153D cannot be revised u/s 263 without first revising the approval itself. The AO conducted adequate and reasonable enquiries, fulfilling the requirements of a proper assessment. - The Tribunal emphasized the legal principle that when two views are possible, the AO's decision to adopt one permissible view cannot be deemed erroneous or prejudicial to the interests of the revenue.
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