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 allowed the assessee's appeal, finding the tax authority's assessment invalid. The court ruled that a statement recorded during a search under Section 132(4) cannot be the sole basis for income addition in block assessment. Section 158BC mandates that undisclosed income additions must be supported by incriminating materials discovered during the search. Furthermore, the court held that surcharge under Section 113 applies only to searches conducted after 01.06.2002, following precedent in Vatika Township case, thus deciding in favor of the assessee.
HC allowed the assessee's appeal, finding the tax authority's assessment invalid. The court ruled that a statement recorded during a search under Section 132(4) cannot be the sole basis for income addition in block assessment. Section 158BC mandates that undisclosed income additions must be supported by incriminating materials discovered during the search. Furthermore, the court held that surcharge under Section 113 applies only to searches conducted after 01.06.2002, following precedent in Vatika Township case, thus deciding in favor of the assessee.
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