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 addressed two issues: disallowance of deduction u/s 10B and non-compliance with Section 153C procedure. Regarding Section 10B, the Court upheld the Tribunal's decision based on its previous judgment in Tata Elxsi Ltd. As for Section 153C, the Court reiterated that when search material is relied upon, the Assessing Officer must follow the procedure u/ss 153A, 153B, and 153C, and cannot continue with regular assessment. The Court relied on its decision in Dinakar Suvarna and ruled in favor of the assessee on both issues.
The High Court addressed two issues: disallowance of deduction u/s 10B and non-compliance with Section 153C procedure. Regarding Section 10B, the Court upheld the Tribunal's decision based on its previous judgment in Tata Elxsi Ltd. As for Section 153C, the Court reiterated that when search material is relied upon, the Assessing Officer must follow the procedure u/ss 153A, 153B, and 153C, and cannot continue with regular assessment. The Court relied on its decision in Dinakar Suvarna and ruled in favor of the assessee on both issues.
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