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 quashed the reference made by respondent no. 1 to respondent no. 2 under s. 92CA, along with the notice and approval granted by the Principal Commissioner of Income Tax dated 24.12.2019. The court found that the petitioner was not provided a proper opportunity to be heard before the case transfer to the TPO, violating para 3.4 of Instruction No. 3 of 2016. The respondent hastily made the proposal on 24.12.2019 after issuing notice under s. 142(1) on 23.12.2019, giving minimal response time. The court determined the purported opportunity of hearing was merely an empty formality, resulting in breach of natural justice principles.
The HC quashed the reference made by respondent no. 1 to respondent no. 2 under s. 92CA, along with the notice and approval granted by the Principal Commissioner of Income Tax dated 24.12.2019. The court found that the petitioner was not provided a proper opportunity to be heard before the case transfer to the TPO, violating para 3.4 of Instruction No. 3 of 2016. The respondent hastily made the proposal on 24.12.2019 after issuing notice under s. 142(1) on 23.12.2019, giving minimal response time. The court determined the purported opportunity of hearing was merely an empty formality, resulting in breach of natural justice principles.
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