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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
HC set aside order denying condonation of 1585-day delay in filing revised return under s.139(5), holding principles of natural justice must be followed despite absence of explicit provision in s.119(2). Natural justice principles should be read into statutory gaps when not explicitly excluded. Matter remanded to CBDT for fresh consideration with directions to provide petitioner hearing opportunity and issue reasoned order within three months. While s.119(2) doesn't specify procedural requirements, decisions with serious civil consequences warrant fair hearing. CBDT must evaluate condonation application afresh following due process, keeping merits open for consideration.
HC set aside order denying condonation of 1585-day delay in filing revised return under s.139(5), holding principles of natural justice must be followed despite absence of explicit provision in s.119(2). Natural justice principles should be read into statutory gaps when not explicitly excluded. Matter remanded to CBDT for fresh consideration with directions to provide petitioner hearing opportunity and issue reasoned order within three months. While s.119(2) doesn't specify procedural requirements, decisions with serious civil consequences warrant fair hearing. CBDT must evaluate condonation application afresh following due process, keeping merits open for consideration.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
