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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The circular enhances monetary limits for filing appeals by the Income Tax Department before Income Tax Appellate Tribunal, High Courts, and Supreme Court. For appeals before ITAT, limit is Rs. 60 lakh, Rs. 2 crore for High Courts, and Rs. 5 crore for Supreme Court. Exceptions apply for cases involving tax deduction/collection at source, where decision is merit-based. Appeals should not be filed solely due to exceeding monetary limits; merits must be considered to reduce unnecessary litigation and provide certainty. Modifications are effective immediately, applying to pending and future appeals, which may be withdrawn if exceeding revised limits.
The circular enhances monetary limits for filing appeals by the Income Tax Department before Income Tax Appellate Tribunal, High Courts, and Supreme Court. For appeals before ITAT, limit is Rs. 60 lakh, Rs. 2 crore for High Courts, and Rs. 5 crore for Supreme Court. Exceptions apply for cases involving tax deduction/collection at source, where decision is merit-based. Appeals should not be filed solely due to exceeding monetary limits; merits must be considered to reduce unnecessary litigation and provide certainty. Modifications are effective immediately, applying to pending and future appeals, which may be withdrawn if exceeding revised limits.
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