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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Petitioner challenged validity of Assessment Order under Income Tax Act on grounds of breach of principles of natural justice and denial of opportunity for personal hearing. Court held that petitioner ought to have been granted opportunity of hearing as provided under Act. Petition succeeded, impugned Assessment Order passed by respondent authority u/s 143(3) read with Section 144B and demand notice u/s 156 quashed and set aside. Respondent granted liberty to proceed with assessment u/s 144B from stage of issuance of draft Assessment Order after providing opportunity of hearing to petitioner, as permissible under law.
Petitioner challenged validity of Assessment Order under Income Tax Act on grounds of breach of principles of natural justice and denial of opportunity for personal hearing. Court held that petitioner ought to have been granted opportunity of hearing as provided under Act. Petition succeeded, impugned Assessment Order passed by respondent authority u/s 143(3) read with Section 144B and demand notice u/s 156 quashed and set aside. Respondent granted liberty to proceed with assessment u/s 144B from stage of issuance of draft Assessment Order after providing opportunity of hearing to petitioner, as permissible under law.
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