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 quashed the order denying waiver of interest charged u/s 234C, holding that the Chief Commissioner of Income Tax failed to consider the petitioner's primary submission attributing the inability to correctly estimate income/profits for paying advance tax to the COVID-19 pandemic. The court observed that the impugned order did not address the petitioner's contentions based on cited decisions or the statutory provisions and scheme of the Income Tax Act relied upon. Consequently, the matter was remanded to the Chief Commissioner for fresh consideration of the waiver application on merits, considering the petitioner's submissions and legal position.
The High Court quashed the order denying waiver of interest charged u/s 234C, holding that the Chief Commissioner of Income Tax failed to consider the petitioner's primary submission attributing the inability to correctly estimate income/profits for paying advance tax to the COVID-19 pandemic. The court observed that the impugned order did not address the petitioner's contentions based on cited decisions or the statutory provisions and scheme of the Income Tax Act relied upon. Consequently, the matter was remanded to the Chief Commissioner for fresh consideration of the waiver application on merits, considering the petitioner's submissions and legal position.
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