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 invalidated reopening of tax assessment, finding procedural violations in notices issued under Sections 148-A and 148. Following precedents from multiple jurisdictions, the court held that assessment notices were improperly served outside the faceless assessment framework mandated by Finance Act, 2021. The jurisdictional Assessing Officer's actions were deemed non-compliant with statutory requirements. Consequently, the writ petition was allowed in favor of the assessee, effectively quashing the tax reassessment proceedings on jurisdictional grounds.
HC invalidated reopening of tax assessment, finding procedural violations in notices issued under Sections 148-A and 148. Following precedents from multiple jurisdictions, the court held that assessment notices were improperly served outside the faceless assessment framework mandated by Finance Act, 2021. The jurisdictional Assessing Officer's actions were deemed non-compliant with statutory requirements. Consequently, the writ petition was allowed in favor of the assessee, effectively quashing the tax reassessment proceedings on jurisdictional grounds.
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