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 allowed petitions challenging CBDT's rejection of applications under Section 119(1) of Income Tax Act for condonation of delay in reassessment. Following CG Power precedent, Court found rejection unsustainable both legally and factually. Petitioner voluntarily waived rights to potential tax refunds through authorized memo dated 15.02.2024, demonstrating commitment to fair assessment without financial implications for Revenue. Court confirmed waiver's validity through Power of Attorney dated 22.11.2013, covering refunds post-adjustment of tax liabilities for AY 2002-03 to 2008-09. Petition granted under Article 226, permitting reassessment with condition of no refund claims, ensuring Revenue faces no additional burden.
HC allowed petitions challenging CBDT's rejection of applications under Section 119(1) of Income Tax Act for condonation of delay in reassessment. Following CG Power precedent, Court found rejection unsustainable both legally and factually. Petitioner voluntarily waived rights to potential tax refunds through authorized memo dated 15.02.2024, demonstrating commitment to fair assessment without financial implications for Revenue. Court confirmed waiver's validity through Power of Attorney dated 22.11.2013, covering refunds post-adjustment of tax liabilities for AY 2002-03 to 2008-09. Petition granted under Article 226, permitting reassessment with condition of no refund claims, ensuring Revenue faces no additional burden.
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