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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Applicability of Section 56(2)(x) and the jurisdiction of the Principal Commissioner of Income Tax (PCIT), Jaipur-1, in revising the order u/s 263. The key points are: The PCIT had appropriate jurisdiction as the assessee failed to provide proof of address change in the PAN database. The contention regarding non-applicability of Section 56(2)(x) was dismissed as the deeds for the property differed in area and consideration, indicating a deviation from the claimed transaction. The assessee failed to clarify or provide evidence that both deeds related to the same property. Details of TDS deduction u/s 194IA were also not provided, further weakening the assessee's case. Consequently, the PCIT's order applying Section 56(2)(x) was upheld by the Appellate Tribunal.
Applicability of Section 56(2)(x) and the jurisdiction of the Principal Commissioner of Income Tax (PCIT), Jaipur-1, in revising the order u/s 263. The key points are: The PCIT had appropriate jurisdiction as the assessee failed to provide proof of address change in the PAN database. The contention regarding non-applicability of Section 56(2)(x) was dismissed as the deeds for the property differed in area and consideration, indicating a deviation from the claimed transaction. The assessee failed to clarify or provide evidence that both deeds related to the same property. Details of TDS deduction u/s 194IA were also not provided, further weakening the assessee's case. Consequently, the PCIT's order applying Section 56(2)(x) was upheld by the Appellate Tribunal.
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