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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ITAT set aside the assessment order dated 23.02.2024 passed u/s 143(3) r.w.s 254 due to violation of principles of natural justice. The Tribunal directed the Assessing Officer to proceed afresh after providing the assessee with an opportunity to rebut evidence and supplying all adverse reports and documents. The limitation period was found valid under the first proviso to section 153(3), with the assessment order being within the prescribed twelve-month timeframe. The assessee's appeal was allowed for statistical purposes, mandating a de novo proceeding with complete procedural fairness.
ITAT set aside the assessment order dated 23.02.2024 passed u/s 143(3) r.w.s 254 due to violation of principles of natural justice. The Tribunal directed the Assessing Officer to proceed afresh after providing the assessee with an opportunity to rebut evidence and supplying all adverse reports and documents. The limitation period was found valid under the first proviso to section 153(3), with the assessment order being within the prescribed twelve-month timeframe. The assessee's appeal was allowed for statistical purposes, mandating a de novo proceeding with complete procedural fairness.
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