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 ruled that the transfer of jurisdiction under Section 127 was improper due to lack of agreement between tax authorities. The search operations at petitioner's premises in 2019, with subsequent assessment orders passed against the party, did not substantiate compelling reasons for jurisdictional transfer. The court quashed the transfer notifications and remitted the cases back to the original Commissioner of Income Tax (Exemptions), directing fresh orders within three months. The petitioners were granted an opportunity to be heard, with consideration of potential loss of faceless assessment benefits under Section 144B of the Income Tax Act.
HC ruled that the transfer of jurisdiction under Section 127 was improper due to lack of agreement between tax authorities. The search operations at petitioner's premises in 2019, with subsequent assessment orders passed against the party, did not substantiate compelling reasons for jurisdictional transfer. The court quashed the transfer notifications and remitted the cases back to the original Commissioner of Income Tax (Exemptions), directing fresh orders within three months. The petitioners were granted an opportunity to be heard, with consideration of potential loss of faceless assessment benefits under Section 144B of the Income Tax Act.
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