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 reassessment proceedings against the Petitioner due to procedural irregularities. The court found significant violations of natural justice, specifically the tax authorities' failure to address the Petitioner's objections before issuing the Assessment Order under Section 147 read with Section 144B of the Income Tax Act. The HC determined that the objections, filed on 30th July 2021, were improperly ignored, and the respondent's claim of no formal objections was factually incorrect. Consequently, the court remanded the matter back to the tax authorities, directing them to first dispose of the Petitioner's objections before proceeding with any further reassessment actions.
HC invalidated reassessment proceedings against the Petitioner due to procedural irregularities. The court found significant violations of natural justice, specifically the tax authorities' failure to address the Petitioner's objections before issuing the Assessment Order under Section 147 read with Section 144B of the Income Tax Act. The HC determined that the objections, filed on 30th July 2021, were improperly ignored, and the respondent's claim of no formal objections was factually incorrect. Consequently, the court remanded the matter back to the tax authorities, directing them to first dispose of the Petitioner's objections before proceeding with any further reassessment actions.
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