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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Settlement applications filed between 01.02.2021 and 31.03.2021, prior to amendment of Section 245C(5) of the Act, are maintainable before the Interim Board for Settlement. Retrospective amendment cannot invalidate applications filed when no prohibitory statute existed. Petitioners had vested right to file applications before 31.03.2021 when amendment took effect. CBDT extending last date to 30.09.2021 for eligible cases as on 31.01.2021 cannot override non-existent Section 245C(5). Applications filed after 01.02.2021 but before 31.03.2021 cannot be invalid. Section 245C(5) rightly read down to apply from 01.04.2021 when assented. Petitions allowed, impugned orders set aside, applications deemed pending for Interim Board's consideration if otherwise eligible. Consequential actions by Assessing Officers quashed. Matter remanded to Interim Board for deciding applications on merits.
Settlement applications filed between 01.02.2021 and 31.03.2021, prior to amendment of Section 245C(5) of the Act, are maintainable before the Interim Board for Settlement. Retrospective amendment cannot invalidate applications filed when no prohibitory statute existed. Petitioners had vested right to file applications before 31.03.2021 when amendment took effect. CBDT extending last date to 30.09.2021 for eligible cases as on 31.01.2021 cannot override non-existent Section 245C(5). Applications filed after 01.02.2021 but before 31.03.2021 cannot be invalid. Section 245C(5) rightly read down to apply from 01.04.2021 when assented. Petitions allowed, impugned orders set aside, applications deemed pending for Interim Board's consideration if otherwise eligible. Consequential actions by Assessing Officers quashed. Matter remanded to Interim Board for deciding applications on merits.
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