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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HC upheld assessment order issued under Section 143(3) read with 144B, finding no violation of natural justice principles. The assessee had received show cause notice and participated in video conferencing hearing, where they explained loan transactions in detail. The Court determined video conferencing was substantive, not merely procedural. Notably, assessee failed to produce relevant documentation supporting their position despite having opportunity. Court emphasized that burden lies with notice recipient to furnish supporting evidence, and assessing officer cannot be expected to specifically request unknown documents. Finding due process requirements satisfied and no procedural violations established, petition dismissed.
HC upheld assessment order issued under Section 143(3) read with 144B, finding no violation of natural justice principles. The assessee had received show cause notice and participated in video conferencing hearing, where they explained loan transactions in detail. The Court determined video conferencing was substantive, not merely procedural. Notably, assessee failed to produce relevant documentation supporting their position despite having opportunity. Court emphasized that burden lies with notice recipient to furnish supporting evidence, and assessing officer cannot be expected to specifically request unknown documents. Finding due process requirements satisfied and no procedural violations established, petition dismissed.
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