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 assessee sought condonation of delay in filing an appeal before the CIT(A)-NFAC, citing illness with Bipolar disorder and residence in USA as reasons for the delay. The CIT(A)-NFAC rejected the assessee's submissions and denied condonation. However, the ITAT, considering the assessee's health condition, condoned the 351-day delay and remitted the matter to the CIT(A)-NFAC for fresh consideration, granting the assessee an opportunity to be heard. The ITAT cautioned the assessee to cooperate promptly, failing which the CIT(A)-NFAC could pass an appropriate order based on available records. The assessee's appeal was allowed for statistical purposes.
The assessee sought condonation of delay in filing an appeal before the CIT(A)-NFAC, citing illness with Bipolar disorder and residence in USA as reasons for the delay. The CIT(A)-NFAC rejected the assessee's submissions and denied condonation. However, the ITAT, considering the assessee's health condition, condoned the 351-day delay and remitted the matter to the CIT(A)-NFAC for fresh consideration, granting the assessee an opportunity to be heard. The ITAT cautioned the assessee to cooperate promptly, failing which the CIT(A)-NFAC could pass an appropriate order based on available records. The assessee's appeal was allowed for statistical purposes.
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