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 held that under Section 9(a)(i) of the Direct Tax Vivad Se Vishwas Act, 2020, declarants are precluded from settling disputes where tax arrears relate to assessments under Sections 143(3), 144, 153A, or 153C following a search under Section 132, and where disputed tax exceeds Rs. 5,00,00,000/-. The petitioners' assessments arising from search proceedings on 24.09.2015 with assessment orders dated 28.04.2017 and 27.04.2017 respectively exceeded the prescribed threshold. Consequently, the petitioners were ineligible for amnesty scheme benefits, irrespective of having paid taxes, consistent with CBDT circulars interpreting the statutory provisions.
HC held that under Section 9(a)(i) of the Direct Tax Vivad Se Vishwas Act, 2020, declarants are precluded from settling disputes where tax arrears relate to assessments under Sections 143(3), 144, 153A, or 153C following a search under Section 132, and where disputed tax exceeds Rs. 5,00,00,000/-. The petitioners' assessments arising from search proceedings on 24.09.2015 with assessment orders dated 28.04.2017 and 27.04.2017 respectively exceeded the prescribed threshold. Consequently, the petitioners were ineligible for amnesty scheme benefits, irrespective of having paid taxes, consistent with CBDT circulars interpreting the statutory provisions.
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