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 dismissed the review petition against its order that had remitted the case for fresh assessment. The court found no grounds for review as the original order was based on a concession by the review petitioner's counsel and the remittance was in accordance with Supreme Court precedent. The petitioner's argument regarding the inapplicability of the proviso to Section 2(15) to their case could not be entertained under review jurisdiction. The court relied on precedents established in Sanjay Kumar Agarwal v. State Tax Officer (1) & Anr. and Rimpa Saha to determine that the case did not fall within the limited scope of review powers.
HC dismissed the review petition against its order that had remitted the case for fresh assessment. The court found no grounds for review as the original order was based on a concession by the review petitioner's counsel and the remittance was in accordance with Supreme Court precedent. The petitioner's argument regarding the inapplicability of the proviso to Section 2(15) to their case could not be entertained under review jurisdiction. The court relied on precedents established in Sanjay Kumar Agarwal v. State Tax Officer (1) & Anr. and Rimpa Saha to determine that the case did not fall within the limited scope of review powers.
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