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 dismissed petition challenging penalty proceedings under s271DA. AO initiated proceedings via reference to Addl. CIT within 11 days of assessment order completion (08.04.2024), following assessment order dated 28.03.2024. Six-month limitation period commenced from reference date. Court held timing reasonable, rejecting petitioner's argument of arbitrary extension. While acknowledging that inordinate delays require scrutiny and reasonable timeframe applies where no specific limitation exists, HC found 11-day gap between assessment completion and penalty initiation well within acceptable bounds. Proceedings deemed within limitation period prescribed under s275(1)(c).
HC dismissed petition challenging penalty proceedings under s271DA. AO initiated proceedings via reference to Addl. CIT within 11 days of assessment order completion (08.04.2024), following assessment order dated 28.03.2024. Six-month limitation period commenced from reference date. Court held timing reasonable, rejecting petitioner's argument of arbitrary extension. While acknowledging that inordinate delays require scrutiny and reasonable timeframe applies where no specific limitation exists, HC found 11-day gap between assessment completion and penalty initiation well within acceptable bounds. Proceedings deemed within limitation period prescribed under s275(1)(c).
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