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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Condonation of delay in filing income tax return (ITR) - Rejection of application made u/s 119(2)(b) - The High court found that the PCIT's order lacked reasoning and did not fulfill the legislative mandate of Section 119(2)(b) of the Income Tax Act, which is designed to address genuine hardship. The court emphasized the importance of reasoned orders and, citing relevant judicial precedents, set aside the impugned order. The matter was remanded to the PCIT for fresh consideration.
Condonation of delay in filing income tax return (ITR) - Rejection of application made u/s 119(2)(b) - The High court found that the PCIT's order lacked reasoning and did not fulfill the legislative mandate of Section 119(2)(b) of the Income Tax Act, which is designed to address genuine hardship. The court emphasized the importance of reasoned orders and, citing relevant judicial precedents, set aside the impugned order. The matter was remanded to the PCIT for fresh consideration.
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