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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The HC upheld reassessment proceedings initiated by the AO against the petitioner based on funds received by NNPLC (petitioner's wholly-owned subsidiary). The AO relied on DRP's view that NNPLC was established without reasonable business purpose and its funds constituted unaccounted income of the petitioner under Section 68. Despite a Special Bench of the Tribunal previously concluding that petitioner had not extended corporate guarantee to NNPLC, the HC determined sufficient material existed to justify reassessment. The court rejected petitioner's argument that DRP's order was misconstrued, noting this contention was not raised in earlier litigation before HC or SC. The SC had previously affirmed the AO's reliance on DRP's order was justified. Challenge to reassessment action dismissed.
The HC upheld reassessment proceedings initiated by the AO against the petitioner based on funds received by NNPLC (petitioner's wholly-owned subsidiary). The AO relied on DRP's view that NNPLC was established without reasonable business purpose and its funds constituted unaccounted income of the petitioner under Section 68. Despite a Special Bench of the Tribunal previously concluding that petitioner had not extended corporate guarantee to NNPLC, the HC determined sufficient material existed to justify reassessment. The court rejected petitioner's argument that DRP's order was misconstrued, noting this contention was not raised in earlier litigation before HC or SC. The SC had previously affirmed the AO's reliance on DRP's order was justified. Challenge to reassessment action dismissed.
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