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 addressed the issuance of notice under Section 153C, holding that the Assessing Officer's (AO) action for the other person shall be limited to six years from the date of receipt of seized material, irrespective of the original search date. The Supreme Court clarified that the date of receipt of seized material cannot be construed as the date of search, and requiring assessees to maintain records for extended periods is impractical. Consequently, the AO is competent to take action only for the six years preceding the receipt of seized material, rendering the search date irrelevant in determining the assessment period.
The ITAT addressed the issuance of notice under Section 153C, holding that the Assessing Officer's (AO) action for the other person shall be limited to six years from the date of receipt of seized material, irrespective of the original search date. The Supreme Court clarified that the date of receipt of seized material cannot be construed as the date of search, and requiring assessees to maintain records for extended periods is impractical. Consequently, the AO is competent to take action only for the six years preceding the receipt of seized material, rendering the search date irrelevant in determining the assessment period.
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