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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Non-filer assessee had taxable income but failed to file return u/s 139(1), later filed return in response to notice u/s 148 without considering section 50C provisions, amounting to concealment of income. Assessee neither filed explanation nor appeared before authorities during assessment or penalty proceedings u/s 271(1)(c) despite show cause notices. No reasonable cause furnished for non-filing of return or non-appearance. Penalty u/s 271(1)(c) confirmed as assessee concealed particulars of income by not adopting section 50C provisions while computing capital gains based on registered sale deed value.
Non-filer assessee had taxable income but failed to file return u/s 139(1), later filed return in response to notice u/s 148 without considering section 50C provisions, amounting to concealment of income. Assessee neither filed explanation nor appeared before authorities during assessment or penalty proceedings u/s 271(1)(c) despite show cause notices. No reasonable cause furnished for non-filing of return or non-appearance. Penalty u/s 271(1)(c) confirmed as assessee concealed particulars of income by not adopting section 50C provisions while computing capital gains based on registered sale deed value.
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