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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This case pertains to the validity of a transfer order u/s 127 of the Income Tax Act, where the petitioner's case was transferred from the Commissioner of Income Tax (CIT), Mumbai, to the Central Circle - 20, Range-5, Principal CIT (Central) - 2, New Delhi. The petitioner challenged the transfer order, alleging a breach of the principles of natural justice as no hearing was granted. The High Court dismissed the writ petition, holding that there was sufficient material justifying the transfer, and the petitioner had acquiesced to the transfer order by participating in subsequent proceedings initiated by the Delhi authorities. The court found no grounds to interfere with the impugned order under Article 226 of the Constitution.
This case pertains to the validity of a transfer order u/s 127 of the Income Tax Act, where the petitioner's case was transferred from the Commissioner of Income Tax (CIT), Mumbai, to the Central Circle - 20, Range-5, Principal CIT (Central) - 2, New Delhi. The petitioner challenged the transfer order, alleging a breach of the principles of natural justice as no hearing was granted. The High Court dismissed the writ petition, holding that there was sufficient material justifying the transfer, and the petitioner had acquiesced to the transfer order by participating in subsequent proceedings initiated by the Delhi authorities. The court found no grounds to interfere with the impugned order under Article 226 of the Constitution.
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