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 transfer of petitioner's income tax assessment file from Coimbatore to Kolkata under Section 127, finding no irregularity in the transfer order. The court determined that centralized investigation for coordinated tax assessment constitutes a valid ground for inter-jurisdictional transfer. Despite potential inconvenience to the petitioner, the transfer was deemed permissible as no prejudicial final assessment order was passed and the transfer served public interest. The writ petition challenging the transfer notification was consequently dismissed.
HC upheld the transfer of petitioner's income tax assessment file from Coimbatore to Kolkata under Section 127, finding no irregularity in the transfer order. The court determined that centralized investigation for coordinated tax assessment constitutes a valid ground for inter-jurisdictional transfer. Despite potential inconvenience to the petitioner, the transfer was deemed permissible as no prejudicial final assessment order was passed and the transfer served public interest. The writ petition challenging the transfer notification was consequently dismissed.
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