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 Deputy Commissioner of Income Tax assessed the applicant at a wrong jurisdiction, leading to a contempt application for disobedience of a High Court order. The DCIT failed to delete outstanding amounts from the web portal despite the court's order, resulting in contempt proceedings. The court found the DCIT guilty of contempt, noting deliberate disobedience. The DCIT was sentenced to a fine of Rs. 25,000 and one week's imprisonment, with further imprisonment for default. The court emphasized the need to uphold the dignity of the law and punished the DCIT for willful misconduct and harassment of the applicant.
The Deputy Commissioner of Income Tax assessed the applicant at a wrong jurisdiction, leading to a contempt application for disobedience of a High Court order. The DCIT failed to delete outstanding amounts from the web portal despite the court's order, resulting in contempt proceedings. The court found the DCIT guilty of contempt, noting deliberate disobedience. The DCIT was sentenced to a fine of Rs. 25,000 and one week's imprisonment, with further imprisonment for default. The court emphasized the need to uphold the dignity of the law and punished the DCIT for willful misconduct and harassment of the applicant.
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