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 held assessment order invalid due to fundamental procedural defects in implementing Faceless Assessment Scheme. Original order failed to qualify as Draft Assessment Order (DAO) under s.144C(1), lacking statutory requirements for assessee response. Department's subsequent corrigendum attempting to retroactively designate order as DAO was ineffective, as 30-day objection period under s.144C(2) had already lapsed. Court rejected Revenue's argument that errors were minor, finding them fundamental to jurisdictional validity. Demand notice under s.156 cannot be nullified through mere corrigendum. Non-compliance with s.144C statutory requirements not protected by s.292BB savings clause. Questions 1-3 answered in assessee's favor, invalidating assessment order.
HC held assessment order invalid due to fundamental procedural defects in implementing Faceless Assessment Scheme. Original order failed to qualify as Draft Assessment Order (DAO) under s.144C(1), lacking statutory requirements for assessee response. Department's subsequent corrigendum attempting to retroactively designate order as DAO was ineffective, as 30-day objection period under s.144C(2) had already lapsed. Court rejected Revenue's argument that errors were minor, finding them fundamental to jurisdictional validity. Demand notice under s.156 cannot be nullified through mere corrigendum. Non-compliance with s.144C statutory requirements not protected by s.292BB savings clause. Questions 1-3 answered in assessee's favor, invalidating assessment order.
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