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 held that the Assessment Order u/s 153C was not time-barred due to COVID-19 related limitation extensions. The statutory period for passing the order would have expired on 31.03.2023, but governmental disruptions and subsequent legislative measures like Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and TOLA 2021 effectively extended the limitation period. The court ruled that the assessment order was within jurisdiction, overruling the petitioner's objection. The respondent shall apply preponderance of probability standard and make efforts to produce the director for cross-examination within six months.
HC held that the Assessment Order u/s 153C was not time-barred due to COVID-19 related limitation extensions. The statutory period for passing the order would have expired on 31.03.2023, but governmental disruptions and subsequent legislative measures like Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and TOLA 2021 effectively extended the limitation period. The court ruled that the assessment order was within jurisdiction, overruling the petitioner's objection. The respondent shall apply preponderance of probability standard and make efforts to produce the director for cross-examination within six months.
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