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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
HC invalidated reassessment proceedings initiated under s148A(b) based on alleged bogus capital expenses identified through CRIU/VRU information. Revenue's physical verification and subsequent order under s148A(d) violated natural justice principles as assessee was not given opportunity to respond to allegations regarding non-existent entity. Court emphasized that post original assessment closure, AO becomes functus officio and jurisdiction for reassessment requires proper disclosure of incriminating material to assessee. Physical verification findings about entity's non-existence at Jasola address were not communicated via show cause notice, making the reassessment proceedings procedurally defective. Order set aside in assessee's favor.
HC invalidated reassessment proceedings initiated under s148A(b) based on alleged bogus capital expenses identified through CRIU/VRU information. Revenue's physical verification and subsequent order under s148A(d) violated natural justice principles as assessee was not given opportunity to respond to allegations regarding non-existent entity. Court emphasized that post original assessment closure, AO becomes functus officio and jurisdiction for reassessment requires proper disclosure of incriminating material to assessee. Physical verification findings about entity's non-existence at Jasola address were not communicated via show cause notice, making the reassessment proceedings procedurally defective. Order set aside in assessee's favor.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
