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 quashed multiple show cause notices (SCNs) due to lack of mandatory pre-SCN consultation as required under Master Circular dated March 10, 2017. The court found the SCNs vague and lacking reference to petitioners' contentions raised during pre-consultation. In one case (SCA 5685/2022), though the SCN contained liability elements, it merely highlighted discrepancies between Form 26AS and ST-3 returns. The subsequent Order-in-Original was also set aside. Department retains liberty to initiate fresh proceedings or revive original SCNs subject to Supreme Court's pending decision. The ruling emphasizes that absence of pre-SCN consultation is fatal to notice validity, following precedent set in L&T Hydrocarbon Engineering Ltd. case.
HC quashed multiple show cause notices (SCNs) due to lack of mandatory pre-SCN consultation as required under Master Circular dated March 10, 2017. The court found the SCNs vague and lacking reference to petitioners' contentions raised during pre-consultation. In one case (SCA 5685/2022), though the SCN contained liability elements, it merely highlighted discrepancies between Form 26AS and ST-3 returns. The subsequent Order-in-Original was also set aside. Department retains liberty to initiate fresh proceedings or revive original SCNs subject to Supreme Court's pending decision. The ruling emphasizes that absence of pre-SCN consultation is fatal to notice validity, following precedent set in L&T Hydrocarbon Engineering Ltd. case.
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