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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The ITAT Amritsar considered an appeal before CIT(A) u/s 249 regarding non-admission of appeal due to non-payment of advance tax u/s 249(4)(b). The assessee claimed no taxable income, citing agricultural income and non-taxable gifts. Documentary evidence was submitted. The Tribunal found the assessee's stance consistent and declared NIL taxable income, indicating no obligation to pay advance tax u/s 207 and sec 209. The CIT(A) was directed to admit the appeal, considering advance tax as NIL. The order was set aside for further verification of evidence and proper opportunity for the assessee. Appeal allowed for statistical purposes.
The ITAT Amritsar considered an appeal before CIT(A) u/s 249 regarding non-admission of appeal due to non-payment of advance tax u/s 249(4)(b). The assessee claimed no taxable income, citing agricultural income and non-taxable gifts. Documentary evidence was submitted. The Tribunal found the assessee's stance consistent and declared NIL taxable income, indicating no obligation to pay advance tax u/s 207 and sec 209. The CIT(A) was directed to admit the appeal, considering advance tax as NIL. The order was set aside for further verification of evidence and proper opportunity for the assessee. Appeal allowed for statistical purposes.
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