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 quashed reassessment notices issued under Sections 148A and 148, holding they violated faceless assessment provisions mandated by Finance Act 2021. The jurisdictional Assessing Officer improperly issued notices that should have been processed through faceless mechanism per Section 151A read with Notification 18/2022. HC followed its precedent in Petitioner A v. ITO, which established such proceedings as invalid for non-compliance with faceless requirements. Despite Revenue's continuous issuance of similar notices across jurisdictions for sixteen months post-judgment, HC disposed matter as covered by established precedent. However, relief granted subject to outcome of pending SLP before SC challenging the precedent judgment, allowing either party to seek revival based on SC's final determination.
HC quashed reassessment notices issued under Sections 148A and 148, holding they violated faceless assessment provisions mandated by Finance Act 2021. The jurisdictional Assessing Officer improperly issued notices that should have been processed through faceless mechanism per Section 151A read with Notification 18/2022. HC followed its precedent in Petitioner A v. ITO, which established such proceedings as invalid for non-compliance with faceless requirements. Despite Revenue's continuous issuance of similar notices across jurisdictions for sixteen months post-judgment, HC disposed matter as covered by established precedent. However, relief granted subject to outcome of pending SLP before SC challenging the precedent judgment, allowing either party to seek revival based on SC's final determination.
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