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 held that no incriminating material was found during income tax search of the assessee on 2.1.2020 for a completed assessment year. Statutory documents like charge sheets in public domain cannot be considered incriminating evidence. Statements from three individuals were deemed bald and did not reveal undisclosed income. The approval under section 153D was granted mechanically without due application of mind, rendering the assessment void ab initio. Consequently, additions made by the Assessing Officer were deleted, and the assessment for Assessment Year 2011-12 was quashed based on the Supreme Court's ratio decidendi in Abhishar Buildwell case.
ITAT held that no incriminating material was found during income tax search of the assessee on 2.1.2020 for a completed assessment year. Statutory documents like charge sheets in public domain cannot be considered incriminating evidence. Statements from three individuals were deemed bald and did not reveal undisclosed income. The approval under section 153D was granted mechanically without due application of mind, rendering the assessment void ab initio. Consequently, additions made by the Assessing Officer were deleted, and the assessment for Assessment Year 2011-12 was quashed based on the Supreme Court's ratio decidendi in Abhishar Buildwell case.
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