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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The HC quashed a penalty order under Section 271AA(1) for violating principles of natural justice. The petitioner challenged the order on grounds that it was passed by an officer who did not conduct the video conference hearing. The court held that personal hearing is essential and cannot be substituted by written arguments, emphasizing that the officer who hears the assessee must be the same who decides the matter. Relying on established precedent, the court ruled that when one person hears and another decides, personal hearing becomes an empty formality. The court directed respondents to ensure compliance with faceless procedure requirements under the amended scheme, mandating that assessing officers conducting video conferences must pass the corresponding orders. The penalty order was set aside and matter remanded for fresh hearing and decision.
The HC quashed a penalty order under Section 271AA(1) for violating principles of natural justice. The petitioner challenged the order on grounds that it was passed by an officer who did not conduct the video conference hearing. The court held that personal hearing is essential and cannot be substituted by written arguments, emphasizing that the officer who hears the assessee must be the same who decides the matter. Relying on established precedent, the court ruled that when one person hears and another decides, personal hearing becomes an empty formality. The court directed respondents to ensure compliance with faceless procedure requirements under the amended scheme, mandating that assessing officers conducting video conferences must pass the corresponding orders. The penalty order was set aside and matter remanded for fresh hearing and decision.
Note: It is a system-generated summary and is for quick reference only.