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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Final assessment order passed u/s 143(3) read with Section 144C(13) subsequent to Dispute Resolution Panel (DRP)/Transfer Pricing Officer (TPO) directions deemed invalid due to non-compliance with statutory provisions. Assessing Officer failed to follow DRP directions and pass rectification order as mandated. TPO issued Order Giving Effect (OGE) to TP adjustments post-DRP directions, forming part of assessment records. However, Assessing Officer's non-compliance constituted gross violation of Section 144C, rendering final assessment order contrary to the Act. Despite Revenue arguing it as a mistake, no efforts were made to rectify within reasonable time, violating law. Final assessment order quashed, assessee favored.
Final assessment order passed u/s 143(3) read with Section 144C(13) subsequent to Dispute Resolution Panel (DRP)/Transfer Pricing Officer (TPO) directions deemed invalid due to non-compliance with statutory provisions. Assessing Officer failed to follow DRP directions and pass rectification order as mandated. TPO issued Order Giving Effect (OGE) to TP adjustments post-DRP directions, forming part of assessment records. However, Assessing Officer's non-compliance constituted gross violation of Section 144C, rendering final assessment order contrary to the Act. Despite Revenue arguing it as a mistake, no efforts were made to rectify within reasonable time, violating law. Final assessment order quashed, assessee favored.
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