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 upheld the validity of a Section 153C notice based on WhatsApp chat evidence. The court determined that the digital communications constituted corroborative documentation of unaccounted cash transactions between connected parties. The WhatsApp chats provided specific details about plot purchases, cash payments, and financial transactions. Digital evidence from mobile devices, laptops, and personal computers, supplemented by employee statements, substantiated the investigative findings. The court found the evidence sufficiently precise and not vague, thereby rejecting the petitioner's challenge to the notice. Consequently, the court declined to grant any relief to the petitioner, affirming the tax authority's actions as legally sound.
HC upheld the validity of a Section 153C notice based on WhatsApp chat evidence. The court determined that the digital communications constituted corroborative documentation of unaccounted cash transactions between connected parties. The WhatsApp chats provided specific details about plot purchases, cash payments, and financial transactions. Digital evidence from mobile devices, laptops, and personal computers, supplemented by employee statements, substantiated the investigative findings. The court found the evidence sufficiently precise and not vague, thereby rejecting the petitioner's challenge to the notice. Consequently, the court declined to grant any relief to the petitioner, affirming the tax authority's actions as legally sound.
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