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 upheld ITAT's decision quashing assessment orders passed u/s 144C(13) following invalid DRP proceedings. The DRP communication failed to comply with prescribed circular requirements as the DIN was handwritten without specified reasons, lacked prior Chief Commissioner approval, and contained interpolated DIN numbers suggesting post-facto generation. The court found DIN ending 1048143460(1) in DRP proceedings dated 19.12.2022 could not have been generated on 21.12.2022, indicating fraudulent interpolation. Assessment orders based on invalid DRP directions were deemed unsustainable. Revenue department was held responsible for non-compliance with departmental circulars. HC imposed costs of Rs. 1,00,000 payable to PM CARES Fund for the false claims made by appellant regarding DIN generation.
HC upheld ITAT's decision quashing assessment orders passed u/s 144C(13) following invalid DRP proceedings. The DRP communication failed to comply with prescribed circular requirements as the DIN was handwritten without specified reasons, lacked prior Chief Commissioner approval, and contained interpolated DIN numbers suggesting post-facto generation. The court found DIN ending 1048143460(1) in DRP proceedings dated 19.12.2022 could not have been generated on 21.12.2022, indicating fraudulent interpolation. Assessment orders based on invalid DRP directions were deemed unsustainable. Revenue department was held responsible for non-compliance with departmental circulars. HC imposed costs of Rs. 1,00,000 payable to PM CARES Fund for the false claims made by appellant regarding DIN generation.
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