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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Section 28A of the Haryana General Sales Tax Act, 1973 dispenses with the requirement of a second notice and opportunity of personal hearing before proceeding with best judgment assessment. However, the Assessing Authority is bound to issue the initial notice for best judgment assessment within the period of five years as prescribed u/s 28(4) of the Act. The Assessing Authority is not required to intimate the basis for arriving at the best judgment assessment or take any other step, except issuing the initial notice within the five-year period. The legislature's use of the word "for" in Section 28A clarifies that the five-year limitation applies to the issuance of the initial notice for best judgment assessment, without the need for additional steps.
Section 28A of the Haryana General Sales Tax Act, 1973 dispenses with the requirement of a second notice and opportunity of personal hearing before proceeding with best judgment assessment. However, the Assessing Authority is bound to issue the initial notice for best judgment assessment within the period of five years as prescribed u/s 28(4) of the Act. The Assessing Authority is not required to intimate the basis for arriving at the best judgment assessment or take any other step, except issuing the initial notice within the five-year period. The legislature's use of the word "for" in Section 28A clarifies that the five-year limitation applies to the issuance of the initial notice for best judgment assessment, without the need for additional steps.
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