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 HC dismissed the petition challenging the order transferring the petitioner's case from the jurisdictional officer in Mumbai to the counterpart in New Delhi u/s 127(2). The HC held the impugned order reasoned that centralised and coordinated investigation was required to protect revenue interests, considering the petitioner's alleged bogus transactions with entities of the 'Pacific Group'. The HC found the reasons relevant and rejected the grounds of lack of reasons and absence of agreement between the two Commissioners. The HC concluded no infirmity warranted interference under extraordinary jurisdiction.
The HC dismissed the petition challenging the order transferring the petitioner's case from the jurisdictional officer in Mumbai to the counterpart in New Delhi u/s 127(2). The HC held the impugned order reasoned that centralised and coordinated investigation was required to protect revenue interests, considering the petitioner's alleged bogus transactions with entities of the 'Pacific Group'. The HC found the reasons relevant and rejected the grounds of lack of reasons and absence of agreement between the two Commissioners. The HC concluded no infirmity warranted interference under extraordinary jurisdiction.
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