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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Assessment order quashed due to breach of principles of natural justice. Standard Operating Procedure mandates seven days' response time to show cause notice, but assessing officer granted only four days, breaching prescribed procedure. This arbitrary exercise of jurisdiction by not following due process resulted in denial of fair and reasonable opportunity to assessee, causing prejudice. High Court held such approach violative of principles of natural justice and quashed assessment order in favor of assessee.
Assessment order quashed due to breach of principles of natural justice. Standard Operating Procedure mandates seven days' response time to show cause notice, but assessing officer granted only four days, breaching prescribed procedure. This arbitrary exercise of jurisdiction by not following due process resulted in denial of fair and reasonable opportunity to assessee, causing prejudice. High Court held such approach violative of principles of natural justice and quashed assessment order in favor of assessee.
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