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 criminal proceedings against assessee under s.276CC of Income Tax Act for willful delay in filing returns. Payment of penalty under Chapter 21 does not preclude prosecution under Chapter 22. Court distinguished from C.P Yogeshwara case where proceedings were quashed due to returns filed before sanction order. Applying s.278E presumption and following Sasi Enterprises precedent, HC ruled assessee must present defense evidence before Magistrate to rebut presumption of culpable mental state. Petition dismissed while preserving right to raise defenses during trial. Court emphasized separate nature of penalty and prosecution provisions under IT Act.
HC upheld criminal proceedings against assessee under s.276CC of Income Tax Act for willful delay in filing returns. Payment of penalty under Chapter 21 does not preclude prosecution under Chapter 22. Court distinguished from C.P Yogeshwara case where proceedings were quashed due to returns filed before sanction order. Applying s.278E presumption and following Sasi Enterprises precedent, HC ruled assessee must present defense evidence before Magistrate to rebut presumption of culpable mental state. Petition dismissed while preserving right to raise defenses during trial. Court emphasized separate nature of penalty and prosecution provisions under IT Act.
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