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 affirmed that recording a satisfaction note is mandatory before initiating proceedings under Section 153C, even when the Assessing Officer for both searched and other persons is identical. The court relied on CBDT Circular No.24/2015, which mandates recording separate satisfaction notes following Apex Court guidelines. The absence of a distinct satisfaction note pertaining to the other person invalidates proceedings under Section 153C. HC upheld the ITAT's order, finding it consistent with established legal principles. The revenue's appeal was dismissed, confirming CIT(Appeals) and ITAT's previous rulings that emphasized the fundamental requirement of a properly documented satisfaction note as a jurisdictional prerequisite for Section 153C actions.
HC affirmed that recording a satisfaction note is mandatory before initiating proceedings under Section 153C, even when the Assessing Officer for both searched and other persons is identical. The court relied on CBDT Circular No.24/2015, which mandates recording separate satisfaction notes following Apex Court guidelines. The absence of a distinct satisfaction note pertaining to the other person invalidates proceedings under Section 153C. HC upheld the ITAT's order, finding it consistent with established legal principles. The revenue's appeal was dismissed, confirming CIT(Appeals) and ITAT's previous rulings that emphasized the fundamental requirement of a properly documented satisfaction note as a jurisdictional prerequisite for Section 153C actions.
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