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 ITAT held that the assumption of jurisdiction by the Range head (Addl. CIT, Range-1, Raipur) to perform Assessing Officer functions under section 2(7A) without an order under section 120(4)(b) was invalid. The tribunal found no legal basis for the range head's jurisdiction, referencing the Jindal Power Ltd. case. The revenue's reliance on CBDT instructions and Notification No. 6/2009 was rejected as insufficient to confer legitimate jurisdictional authority. Consequently, the assessment order dated 03.02.2014 framed under section 144 was quashed due to lack of inherent jurisdictional competence.
The ITAT held that the assumption of jurisdiction by the Range head (Addl. CIT, Range-1, Raipur) to perform Assessing Officer functions under section 2(7A) without an order under section 120(4)(b) was invalid. The tribunal found no legal basis for the range head's jurisdiction, referencing the Jindal Power Ltd. case. The revenue's reliance on CBDT instructions and Notification No. 6/2009 was rejected as insufficient to confer legitimate jurisdictional authority. Consequently, the assessment order dated 03.02.2014 framed under section 144 was quashed due to lack of inherent jurisdictional competence.
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