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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Advance tax payment obligation does not apply when assessee claims agricultural land sale proceeds are exempt u/s 2(14). CIT(Appeals) should admit appeal for adjudication on merits, treating advance tax payable as nil where assessee claims no taxable income. Dismissing appeal for non-payment of advance tax on disputed demand violates right of appeal when assessee disputes tax liability itself. Tribunal directed CIT(Appeals) to admit appeal and decide on merits, following precedents that right of appeal cannot be denied merely for non-payment of admitted tax due when liability itself is under dispute.
Advance tax payment obligation does not apply when assessee claims agricultural land sale proceeds are exempt u/s 2(14). CIT(Appeals) should admit appeal for adjudication on merits, treating advance tax payable as nil where assessee claims no taxable income. Dismissing appeal for non-payment of advance tax on disputed demand violates right of appeal when assessee disputes tax liability itself. Tribunal directed CIT(Appeals) to admit appeal and decide on merits, following precedents that right of appeal cannot be denied merely for non-payment of admitted tax due when liability itself is under dispute.
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