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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ITAT held that assessment order dated 27/09/2021 against dissolved company lacks legal enforceability. During insolvency proceedings, tax department's claim of Rs. 10.14 Cr for TDS violations was rejected, with subsequent NCLAT dismissal. Approved resolution plan explicitly extinguished all revenue department dues prior to NCLT approval date. Following established jurisprudence, tribunal determined assessment order lost legal sanctity post-dissolution. Department's grounds challenging CIT(A) order deemed non-sustainable. Appeal dismissed as resolution plan's approval effectively extinguished pre-existing tax liabilities.
ITAT held that assessment order dated 27/09/2021 against dissolved company lacks legal enforceability. During insolvency proceedings, tax department's claim of Rs. 10.14 Cr for TDS violations was rejected, with subsequent NCLAT dismissal. Approved resolution plan explicitly extinguished all revenue department dues prior to NCLT approval date. Following established jurisprudence, tribunal determined assessment order lost legal sanctity post-dissolution. Department's grounds challenging CIT(A) order deemed non-sustainable. Appeal dismissed as resolution plan's approval effectively extinguished pre-existing tax liabilities.
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