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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Qualification criteria for being an 'informant' under the Income Tax Informants Reward Scheme, 2018. The key points are: the information provided by the petitioner regarding cash deposits and repayment of deposits in violation of Sections 269SS and 269T was already known to the Assessing Officer during the assessment proceedings. Therefore, it cannot be considered as 'undisclosed income and wealth' eligible for reward under the Scheme. Additionally, the information did not lead to the detection of 'substantial tax evasion', which is a prerequisite for receiving the reward. The High Court held that since the transactions were reflected in the books and examined during assessment, the information provided by the petitioner was not new or undisclosed. The Tribunal's findings also did not support allegations of undisclosed income and tax evasion. Consequently, the petitioner's claim for a reward was rejected.
Qualification criteria for being an 'informant' under the Income Tax Informants Reward Scheme, 2018. The key points are: the information provided by the petitioner regarding cash deposits and repayment of deposits in violation of Sections 269SS and 269T was already known to the Assessing Officer during the assessment proceedings. Therefore, it cannot be considered as 'undisclosed income and wealth' eligible for reward under the Scheme. Additionally, the information did not lead to the detection of 'substantial tax evasion', which is a prerequisite for receiving the reward. The High Court held that since the transactions were reflected in the books and examined during assessment, the information provided by the petitioner was not new or undisclosed. The Tribunal's findings also did not support allegations of undisclosed income and tax evasion. Consequently, the petitioner's claim for a reward was rejected.
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