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 Assessing Officer (AO) initiated reassessment proceedings u/s 147/148 against the assessee based on documents seized from the premises of J.K. Jain during a CBI search. The ITAT found that the AO passed the final reassessment order on the dictates and directions of superior authorities, compromising the independent exercise of quasi-judicial powers. The AO sought guidance from superiors at every stage, even drafting the questionnaire and skeleton order on their instructions. The proceedings were vitiated as the AO discussed the merits and conducted the proceedings under influence, contrary to the requirement of acting judicially and independently. The HC upheld the ITAT's findings, concluding that the reassessment order was the outcome of bias, as it was passed on dictation from higher authorities. Furthermore, the delay in framing the reassessment order exceeded the statutory limitation u/s 153.
The Assessing Officer (AO) initiated reassessment proceedings u/s 147/148 against the assessee based on documents seized from the premises of J.K. Jain during a CBI search. The ITAT found that the AO passed the final reassessment order on the dictates and directions of superior authorities, compromising the independent exercise of quasi-judicial powers. The AO sought guidance from superiors at every stage, even drafting the questionnaire and skeleton order on their instructions. The proceedings were vitiated as the AO discussed the merits and conducted the proceedings under influence, contrary to the requirement of acting judicially and independently. The HC upheld the ITAT's findings, concluding that the reassessment order was the outcome of bias, as it was passed on dictation from higher authorities. Furthermore, the delay in framing the reassessment order exceeded the statutory limitation u/s 153.
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