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 Best Judgment Assessment order under section 144, finding it legally untenable as the Assessing Officer failed to properly consider the petitioner's voluminous reply to the show cause notice. While the AO claimed to have found the reply unsatisfactory, no reasons were provided for this conclusion. Following Supreme Court precedent in M/S SHUKLA & BROTHERS, the matter was remanded for a fresh de novo assessment. The AO must provide the petitioner with a hearing opportunity if requested, consider their submissions, and issue a reasoned order within 12 weeks of receiving the court's decision.
The HC quashed the Best Judgment Assessment order under section 144, finding it legally untenable as the Assessing Officer failed to properly consider the petitioner's voluminous reply to the show cause notice. While the AO claimed to have found the reply unsatisfactory, no reasons were provided for this conclusion. Following Supreme Court precedent in M/S SHUKLA & BROTHERS, the matter was remanded for a fresh de novo assessment. The AO must provide the petitioner with a hearing opportunity if requested, consider their submissions, and issue a reasoned order within 12 weeks of receiving the court's decision.
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