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 High Court directed the Principal Commissioner of Income Tax, Guwahati, to ensure disposal of the petitioner's appeals filed for assessment years 2020-21 and 2018-19 within three months. The court observed that u/s 250(6A) of the Income Tax Act, 1961, the Commissioner (Appeals) must decide appeals within one year from the end of the financial year in which they are filed. Considering the statutory mandate and guidelines, the court opined that the First Appellate Authority should not face difficulty in deciding the appeals expeditiously. The court also noted that no recovery has been made so far and ordered that no coercive measures be taken against the petitioner regarding the demands under appeal until their disposal.
The High Court directed the Principal Commissioner of Income Tax, Guwahati, to ensure disposal of the petitioner's appeals filed for assessment years 2020-21 and 2018-19 within three months. The court observed that u/s 250(6A) of the Income Tax Act, 1961, the Commissioner (Appeals) must decide appeals within one year from the end of the financial year in which they are filed. Considering the statutory mandate and guidelines, the court opined that the First Appellate Authority should not face difficulty in deciding the appeals expeditiously. The court also noted that no recovery has been made so far and ordered that no coercive measures be taken against the petitioner regarding the demands under appeal until their disposal.
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