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 High Court dismissed a challenge to a recovery notice u/s 10 years after assessment/re-assessment orders were passed. The petitioner did not appeal timely, leading to dismissal of the Writ Petition. The respondent's lack of counter affidavit did not affect the decision. The court found no merit in the petition due to the petitioner's failure to appeal the assessment/re-assessment orders for multiple Assessment Years. The Writ Petition was dismissed accordingly.
The High Court dismissed a challenge to a recovery notice u/s 10 years after assessment/re-assessment orders were passed. The petitioner did not appeal timely, leading to dismissal of the Writ Petition. The respondent's lack of counter affidavit did not affect the decision. The court found no merit in the petition due to the petitioner's failure to appeal the assessment/re-assessment orders for multiple Assessment Years. The Writ Petition was dismissed accordingly.
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