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 order passed u/s 153C read with Section 143(3) - whether question of law can directly be raised before High Court without being averred or pleaded before Income Tax Appellate Tribunal (ITAT)? Held that as per K. Lubna & Ors. Versus Beevi & Ors. [2020 (1) TMI 1209 - Supreme Court], parties cannot be restrained from raising a question of law even at the last stage of adjudication. In the present case, Revenue raised substantial questions of law which were not decided by ITAT due to lack of averment or arguments before ITAT. Therefore, Court remanded the appeal back to ITAT with direction to decide afresh after giving opportunity of hearing to parties and pass a speaking and well-reasoned order on merits within two months.
Validity of order passed u/s 153C read with Section 143(3) - whether question of law can directly be raised before High Court without being averred or pleaded before Income Tax Appellate Tribunal (ITAT)? Held that as per K. Lubna & Ors. Versus Beevi & Ors. [2020 (1) TMI 1209 - Supreme Court], parties cannot be restrained from raising a question of law even at the last stage of adjudication. In the present case, Revenue raised substantial questions of law which were not decided by ITAT due to lack of averment or arguments before ITAT. Therefore, Court remanded the appeal back to ITAT with direction to decide afresh after giving opportunity of hearing to parties and pass a speaking and well-reasoned order on merits within two months.
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