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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Revision u/s 263 regarding claim of accommodation entry - reliance on statements of third parties. Timelines for completing assessment u/s 143(3). Assessing officer duly inquired into claim of accommodation entry during Section 147 proceedings. Principal Commissioner of Income Tax (PCIT) did not provide specific findings on how assessment order was erroneous and prejudicial to revenue's interest. PCIT resorted to Section 263 proceedings to extend timelines for framing assessment u/s 147, which is impermissible. PCIT should have conducted necessary inquiries or verification to show Assessing Officer's findings were unsustainable. PCIT failed to provide independent finding on how assessment order was legally unsustainable based on available information. Assessee submitted no long-term capital gains earned during the year, only short-term capital gains on which taxes were paid. Assessee's appeal allowed by Income Tax Appellate Tribunal (ITAT).
Revision u/s 263 regarding claim of accommodation entry - reliance on statements of third parties. Timelines for completing assessment u/s 143(3). Assessing officer duly inquired into claim of accommodation entry during Section 147 proceedings. Principal Commissioner of Income Tax (PCIT) did not provide specific findings on how assessment order was erroneous and prejudicial to revenue's interest. PCIT resorted to Section 263 proceedings to extend timelines for framing assessment u/s 147, which is impermissible. PCIT should have conducted necessary inquiries or verification to show Assessing Officer's findings were unsustainable. PCIT failed to provide independent finding on how assessment order was legally unsustainable based on available information. Assessee submitted no long-term capital gains earned during the year, only short-term capital gains on which taxes were paid. Assessee's appeal allowed by Income Tax Appellate Tribunal (ITAT).
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