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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CIT(A) erred in directing reassessment under Section 194C after High Court quashed original assessment order under Section 194I. While CIT(A) holds powers coextensive with AO under Section 251 including enhancement and reduction of assessment, these powers can only be exercised when there exists a valid, enforceable order under appeal. Once HC quashed the underlying AO order regarding TDS on External Development Charges, CIT(A) lacked jurisdiction to direct recomputation under different provisions. The attempted change from Section 194I to Section 194C assessment was invalid absent an existing enforceable order. ITAT allowed assessee's appeal, holding CIT(A)'s direction for demand recomputation legally untenable.
CIT(A) erred in directing reassessment under Section 194C after High Court quashed original assessment order under Section 194I. While CIT(A) holds powers coextensive with AO under Section 251 including enhancement and reduction of assessment, these powers can only be exercised when there exists a valid, enforceable order under appeal. Once HC quashed the underlying AO order regarding TDS on External Development Charges, CIT(A) lacked jurisdiction to direct recomputation under different provisions. The attempted change from Section 194I to Section 194C assessment was invalid absent an existing enforceable order. ITAT allowed assessee's appeal, holding CIT(A)'s direction for demand recomputation legally untenable.
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