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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Proceedings initiated u/s 148, assessee did not file return of income. Petitioner stated undisclosed interest income, annexed income computation statement, tax paid challan, sale deed, bank statements. Assessing officer noted sale deed, interest income contention but failed to consider challan, TDS. Assessee's failure to reply to show cause notice. Assessment order set aside on condition of paying Rs. 15,000 costs to Tamil Nadu State Legal Services Authority within two weeks. Petitioner permitted to reply to show cause notice, respondents directed to provide portal access.
Proceedings initiated u/s 148, assessee did not file return of income. Petitioner stated undisclosed interest income, annexed income computation statement, tax paid challan, sale deed, bank statements. Assessing officer noted sale deed, interest income contention but failed to consider challan, TDS. Assessee's failure to reply to show cause notice. Assessment order set aside on condition of paying Rs. 15,000 costs to Tamil Nadu State Legal Services Authority within two weeks. Petitioner permitted to reply to show cause notice, respondents directed to provide portal access.
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