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 allowed the petition challenging the rejection of delay condonation for filing revised income tax return for AY 2019-20. The court found that the petitioner's inability to file the revised return was due to pending delay condonation for earlier assessment years. The impugned order dated 05.09.2023 was quashed and the matter remanded to the respondent to pass a fresh order condoning the delay within 12 weeks, considering the PCIT's recommendation and the interconnected nature of the revised return filing across multiple assessment years.
HC allowed the petition challenging the rejection of delay condonation for filing revised income tax return for AY 2019-20. The court found that the petitioner's inability to file the revised return was due to pending delay condonation for earlier assessment years. The impugned order dated 05.09.2023 was quashed and the matter remanded to the respondent to pass a fresh order condoning the delay within 12 weeks, considering the PCIT's recommendation and the interconnected nature of the revised return filing across multiple assessment years.
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