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 writ petition challenging reassessment proceedings under Section 147. Court declined jurisdiction noting petitioner's failure to raise TOLA provisions applicability in initial objections, making it inappropriate to address first time in writ. Questions about Section 54F deductions and rental income taxation involved factual determinations unsuitable for writ jurisdiction. While audit-based reopening was contested, Court held distinction between fact-based and law-based audit objections requires factual examination. Petitioner's participation in proceedings without timely objections weakened procedural challenges. Court granted 4-week extension of interim relief for appeal filing and stay application, directing appellate authority to consider all grounds including procedural objections.
HC dismissed writ petition challenging reassessment proceedings under Section 147. Court declined jurisdiction noting petitioner's failure to raise TOLA provisions applicability in initial objections, making it inappropriate to address first time in writ. Questions about Section 54F deductions and rental income taxation involved factual determinations unsuitable for writ jurisdiction. While audit-based reopening was contested, Court held distinction between fact-based and law-based audit objections requires factual examination. Petitioner's participation in proceedings without timely objections weakened procedural challenges. Court granted 4-week extension of interim relief for appeal filing and stay application, directing appellate authority to consider all grounds including procedural objections.
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