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 the transfer of the petitioner's case from Vadodara to Pune under s.127 of the Income Tax Act. The Court determined that the corrigendum order providing further opportunity of hearing was valid and in continuation of the original transfer order, aimed at fulfilling statutory requirements for reasonable hearing opportunity. The petitioner's contention that the corrigendum notice was without jurisdiction was rejected, particularly as the petitioner failed to respond to the notice. The Court found the transfer justified based on suspicious cash transactions with M/s. G.K. Associates assessed in Pune, noting that transfer powers under s.127 involve public interest considerations and assessees cannot select their Assessing Officer.
The HC upheld the transfer of the petitioner's case from Vadodara to Pune under s.127 of the Income Tax Act. The Court determined that the corrigendum order providing further opportunity of hearing was valid and in continuation of the original transfer order, aimed at fulfilling statutory requirements for reasonable hearing opportunity. The petitioner's contention that the corrigendum notice was without jurisdiction was rejected, particularly as the petitioner failed to respond to the notice. The Court found the transfer justified based on suspicious cash transactions with M/s. G.K. Associates assessed in Pune, noting that transfer powers under s.127 involve public interest considerations and assessees cannot select their Assessing Officer.
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