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 held that Section 154's rectification scope extends to legitimate claims omitted from income tax returns, rejecting the tribunal's narrow interpretation. The court determined that 'record' under Section 154 encompasses financial statements and books of accounts across assessment years, not limited to the specific year under review. Upon verification of ledger accounts demonstrating payment of Rs. 95,36,264/- (including Rs. 65,22,000/- on 20.11.1997), the HC overturned the tribunal's order. The court emphasized that mechanical objections should not defeat Section 154's remedial purpose and confirmed the assessee's right to claim previously omitted surcharge payments through rectification proceedings, even when such claims were not included in the original return.
HC held that Section 154's rectification scope extends to legitimate claims omitted from income tax returns, rejecting the tribunal's narrow interpretation. The court determined that 'record' under Section 154 encompasses financial statements and books of accounts across assessment years, not limited to the specific year under review. Upon verification of ledger accounts demonstrating payment of Rs. 95,36,264/- (including Rs. 65,22,000/- on 20.11.1997), the HC overturned the tribunal's order. The court emphasized that mechanical objections should not defeat Section 154's remedial purpose and confirmed the assessee's right to claim previously omitted surcharge payments through rectification proceedings, even when such claims were not included in the original return.
Note: It is a system-generated summary and is for quick reference only.