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 considered the condonation of a 335-day delay in filing an appeal before the CIT (A). The assessee's explanation, including difficulties related to obtaining documents from Norway and the impact of the Covid-19 pandemic, was deemed sufficient. The Tribunal found no intentional delay or negligence on the part of the assessee. Citing Supreme Court precedent, the Tribunal disagreed with the First Appellate Authority's rejection of the explanation. The case was remitted to the CIT (A) for fresh adjudication, with the directive to consider all relevant evidence and provide the assessee with a hearing. The appeal was allowed for statistical purposes.
The Appellate Tribunal considered the condonation of a 335-day delay in filing an appeal before the CIT (A). The assessee's explanation, including difficulties related to obtaining documents from Norway and the impact of the Covid-19 pandemic, was deemed sufficient. The Tribunal found no intentional delay or negligence on the part of the assessee. Citing Supreme Court precedent, the Tribunal disagreed with the First Appellate Authority's rejection of the explanation. The case was remitted to the CIT (A) for fresh adjudication, with the directive to consider all relevant evidence and provide the assessee with a hearing. The appeal was allowed for statistical purposes.
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