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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CIT(A) allowed assessee to withdraw appeal against section 263 revision order, stating Tribunal quashed section 263 order and CIT(A) erred in not deciding appeal merits. Revenue contended CIT(A) lacks power to allow withdrawal without deciding merits. CIT(A) discussed power u/s 251 to confirm, reduce, enhance or annul assessment while deciding appeal u/s 246A within section 251(1)(a) purview. CIT(A) relied on Bombay High Court decision holding withdrawal power not u/s 251(1)(a) and CIT(A) must decide merits. CIT(A) stated despite withdrawal application, appeal cannot be dismissed without merits examination. Since section 263 revisionary order quashed, consequential section 143(3) order would not survive legally, rightly held by CIT(A). No justification for Revenue's objection that appeal not dismissed based on withdrawal application, finding no merits in Revenue's grounds of appeal.
CIT(A) allowed assessee to withdraw appeal against section 263 revision order, stating Tribunal quashed section 263 order and CIT(A) erred in not deciding appeal merits. Revenue contended CIT(A) lacks power to allow withdrawal without deciding merits. CIT(A) discussed power u/s 251 to confirm, reduce, enhance or annul assessment while deciding appeal u/s 246A within section 251(1)(a) purview. CIT(A) relied on Bombay High Court decision holding withdrawal power not u/s 251(1)(a) and CIT(A) must decide merits. CIT(A) stated despite withdrawal application, appeal cannot be dismissed without merits examination. Since section 263 revisionary order quashed, consequential section 143(3) order would not survive legally, rightly held by CIT(A). No justification for Revenue's objection that appeal not dismissed based on withdrawal application, finding no merits in Revenue's grounds of appeal.
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