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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Assessment u/s 153C - Unexplained investment being share capital and share premium - no incriminating material seized during search. CIT(A) held that three conditions u/s 153C not satisfied cumulatively and simultaneously. No incriminating document found as a result of search, no satisfaction recorded for relevant assessment years. Non-satisfaction of pre-conditions in Section 153C renders notice legally unsustainable. Ratio of Sinhagad Technical Education Society and Index Security Pvt. Ltd. applied. Validity of notice u/s 153C barred by limitation - Search on 11.11.2014, satisfaction recorded on 02.12.2016. Block of 6 years for searched person from AY preceding search year. For person other than searched person, block of 6 years preceding year of recording satisfaction. AY 2009-10 and 2010-11 out of block, assessment order quashed being invalid. Ratio of Jasjit Singh followed. Decided in favor of assessee.
Assessment u/s 153C - Unexplained investment being share capital and share premium - no incriminating material seized during search. CIT(A) held that three conditions u/s 153C not satisfied cumulatively and simultaneously. No incriminating document found as a result of search, no satisfaction recorded for relevant assessment years. Non-satisfaction of pre-conditions in Section 153C renders notice legally unsustainable. Ratio of Sinhagad Technical Education Society and Index Security Pvt. Ltd. applied. Validity of notice u/s 153C barred by limitation - Search on 11.11.2014, satisfaction recorded on 02.12.2016. Block of 6 years for searched person from AY preceding search year. For person other than searched person, block of 6 years preceding year of recording satisfaction. AY 2009-10 and 2010-11 out of block, assessment order quashed being invalid. Ratio of Jasjit Singh followed. Decided in favor of assessee.
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