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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Validity of notice issued u/s 148 in absence of Document Identification Number (DIN) was rejected. The Court observed interim stay by Supreme Court on Delhi High Court's order favouring assessee on DIN issue. Assessee's contention of invalidity of notice u/s 148 without DIN was rejected, relying on Section 292BB deeming notice as served when assessee participates in proceedings. Assessee's explanation of cash deposits from sale of agricultural land was rejected as unregistered agreement contradicted registered sale deed. Addition of cash deposits as income was upheld. Penalty u/s 271(1)(c) for concealment of income was upheld as assessee failed to substantiate source of cash deposits.
Validity of notice issued u/s 148 in absence of Document Identification Number (DIN) was rejected. The Court observed interim stay by Supreme Court on Delhi High Court's order favouring assessee on DIN issue. Assessee's contention of invalidity of notice u/s 148 without DIN was rejected, relying on Section 292BB deeming notice as served when assessee participates in proceedings. Assessee's explanation of cash deposits from sale of agricultural land was rejected as unregistered agreement contradicted registered sale deed. Addition of cash deposits as income was upheld. Penalty u/s 271(1)(c) for concealment of income was upheld as assessee failed to substantiate source of cash deposits.
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