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 Appellate Tribunal held that the non-admission of appeal for non-payment of advance tax u/s 249(4)(b) was not justified. The assessee declared no taxable income, only agricultural income exempted under the Act 61. The computation showed non-taxable income and no liability to pay advance tax u/s 207 and 209. The CIT(A) should have admitted the appeal for adjudication on merits. The order was set aside, and the case was restored for proper verification and hearing, with the amount of advance tax payable considered as NIL. The appeal of the assessee was allowed for statistical purposes.
The Appellate Tribunal held that the non-admission of appeal for non-payment of advance tax u/s 249(4)(b) was not justified. The assessee declared no taxable income, only agricultural income exempted under the Act 61. The computation showed non-taxable income and no liability to pay advance tax u/s 207 and 209. The CIT(A) should have admitted the appeal for adjudication on merits. The order was set aside, and the case was restored for proper verification and hearing, with the amount of advance tax payable considered as NIL. The appeal of the assessee was allowed for statistical purposes.
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