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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Faceless assessment regime introduced new procedures codified u/s 144B for assessments u/ss 143(3), 144, and 147, while assessments u/s 144C (transfer pricing cases) followed existing procedures. Draft assessment orders issued by National Faceless Assessment Centre (NFAC) provide opportunity for assessee's objections before finalization. Jurisdictional Assessing Officer's finalization of assessment order without NFAC involvement was an administrative measure. Dispute Resolution Panel's directions on Section 144B violations not binding on Assessing Officer. Addition u/s 68 on share capital from non-resident Associated Enterprises deleted as identity, creditworthiness, and genuineness established through remittances and previous investments. Belated remittance of employees' ESI/PF contributions disallowed based on Supreme Court's decision in Checkmate Services case.
Faceless assessment regime introduced new procedures codified u/s 144B for assessments u/ss 143(3), 144, and 147, while assessments u/s 144C (transfer pricing cases) followed existing procedures. Draft assessment orders issued by National Faceless Assessment Centre (NFAC) provide opportunity for assessee's objections before finalization. Jurisdictional Assessing Officer's finalization of assessment order without NFAC involvement was an administrative measure. Dispute Resolution Panel's directions on Section 144B violations not binding on Assessing Officer. Addition u/s 68 on share capital from non-resident Associated Enterprises deleted as identity, creditworthiness, and genuineness established through remittances and previous investments. Belated remittance of employees' ESI/PF contributions disallowed based on Supreme Court's decision in Checkmate Services case.
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