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The Supreme Court disposed of the special leave petition as withdrawn, allowing the petitioner to raise the contention regarding the validity of sanction granted by the competent authority before issuing the notice of reopening assessment u/s 147 before the High Court through an appropriate application. The High Court had previously held that the Additional Commissioner of Income Tax had applied their mind and granted sanction in an integrated exercise, conveying satisfaction to the Assessing Officer separately. The High Court found no reason to believe there was a non-application of mind. However, the petitioner contended that this factual issue was raised before the High Court but not considered in the impugned judgment. The Supreme Court noted that while this contention was recorded in its order issuing notice, it was not agitated before the High Court according to the impugned judgment. Since the petitioner submitted that the contention was indeed raised at the hearing but not noted by the High Court, the Supreme Court permitted the petitioner to withdraw the special leave petition and file an appropriate application before the High Court to address this issue.
The Supreme Court disposed of the special leave petition as withdrawn, allowing the petitioner to raise the contention regarding the validity of sanction granted by the competent authority before issuing the notice of reopening assessment u/s 147 before the High Court through an appropriate application. The High Court had previously held that the Additional Commissioner of Income Tax had applied their mind and granted sanction in an integrated exercise, conveying satisfaction to the Assessing Officer separately. The High Court found no reason to believe there was a non-application of mind. However, the petitioner contended that this factual issue was raised before the High Court but not considered in the impugned judgment. The Supreme Court noted that while this contention was recorded in its order issuing notice, it was not agitated before the High Court according to the impugned judgment. Since the petitioner submitted that the contention was indeed raised at the hearing but not noted by the High Court, the Supreme Court permitted the petitioner to withdraw the special leave petition and file an appropriate application before the High Court to address this issue.
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