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 dismissed petitioner's challenge to warrant of authorization regarding seizure of gold jewellery worth Rs. 1,07,70,042. Following seizure, Income Tax Authority served notices under Sections 142(1) and 143(2) of Income Tax Act, passed final assessment order on 24.12.2019 creating demand of Rs. 1.08 crores. Petitioner's appeal against assessment order was dismissed. Court held petitioner cannot challenge warrant of authorization after finalization of assessment proceedings and dismissal of appeal. Income Tax Authority properly rejected release application due to pending tax demand. Court ruled petition misconceived as proper remedy lies before Income Tax Appellate Tribunal under Section 132-B of Income Tax Act. Petition dismissed.
HC dismissed petitioner's challenge to warrant of authorization regarding seizure of gold jewellery worth Rs. 1,07,70,042. Following seizure, Income Tax Authority served notices under Sections 142(1) and 143(2) of Income Tax Act, passed final assessment order on 24.12.2019 creating demand of Rs. 1.08 crores. Petitioner's appeal against assessment order was dismissed. Court held petitioner cannot challenge warrant of authorization after finalization of assessment proceedings and dismissal of appeal. Income Tax Authority properly rejected release application due to pending tax demand. Court ruled petition misconceived as proper remedy lies before Income Tax Appellate Tribunal under Section 132-B of Income Tax Act. Petition dismissed.
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