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 dismissed the petition challenging a notification dated March 26, 2014, which revoked an earlier approval notification from November 17, 2006, regarding deductions under Section 80IA. The court found no merit in petitioners' contention that CBDT lacked authority to issue the revocation notification. The court declined to address the substantive merits of assessment or reassessment, noting these were factual disputes inappropriate for determination at this stage. While rejecting the challenges to the notification and reassessment notices, the court directed respondents to consider petitioners' representations with due regard to the Empowered Committee meeting minutes from November 11, 2014, without being influenced by the petition's dismissal.
The HC dismissed the petition challenging a notification dated March 26, 2014, which revoked an earlier approval notification from November 17, 2006, regarding deductions under Section 80IA. The court found no merit in petitioners' contention that CBDT lacked authority to issue the revocation notification. The court declined to address the substantive merits of assessment or reassessment, noting these were factual disputes inappropriate for determination at this stage. While rejecting the challenges to the notification and reassessment notices, the court directed respondents to consider petitioners' representations with due regard to the Empowered Committee meeting minutes from November 11, 2014, without being influenced by the petition's dismissal.
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