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 quashed the assessment order where the case was transferred from NFAC to ACIT Cent-1, Rajkot without proper notice under s.127. The petitioner was not informed about the transfer except through a mention in the show-cause notice, and was denied personal hearing through video conferencing. The court rejected the respondent's contention that video conferencing was unavailable after transfer to Central Circle, finding this violated principles of natural justice. The matter was remanded to the AO for a fresh de-novo assessment after providing proper hearing opportunity to the petitioner.
HC quashed the assessment order where the case was transferred from NFAC to ACIT Cent-1, Rajkot without proper notice under s.127. The petitioner was not informed about the transfer except through a mention in the show-cause notice, and was denied personal hearing through video conferencing. The court rejected the respondent's contention that video conferencing was unavailable after transfer to Central Circle, finding this violated principles of natural justice. The matter was remanded to the AO for a fresh de-novo assessment after providing proper hearing opportunity to the petitioner.
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