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 rejected the review petition challenging its previous order treating the ITR under Section 139 as "non-est." The Court held that not answering a substantial question regarding the applicability of specific clauses of Section 158-BB did not constitute grounds for review, as this point was left open for the Appellate Tribunal to determine after remand. The Court found no error apparent on the face of the record in its earlier judgment that would justify exercise of review jurisdiction, despite the petitioner's argument about double jeopardy between regular proceedings and block assessment proceedings. The Court distinguished between the scope of review proceedings and statutory appeal, concluding that the effect of its order on subsequent proceedings would be addressed in the connected Income Tax Appeal.
The HC rejected the review petition challenging its previous order treating the ITR under Section 139 as "non-est." The Court held that not answering a substantial question regarding the applicability of specific clauses of Section 158-BB did not constitute grounds for review, as this point was left open for the Appellate Tribunal to determine after remand. The Court found no error apparent on the face of the record in its earlier judgment that would justify exercise of review jurisdiction, despite the petitioner's argument about double jeopardy between regular proceedings and block assessment proceedings. The Court distinguished between the scope of review proceedings and statutory appeal, concluding that the effect of its order on subsequent proceedings would be addressed in the connected Income Tax Appeal.
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