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 disposed of writ petitions filed by a Khasi Scheduled Tribe member seeking stay of recovery proceedings under Section 156 and directions against freezing bank accounts or attachment of assets pending appeals under Section 246A. Despite settled law prohibiting pursuit of dual remedies for the same matter, HC entertained petitions considering pending appeals awaiting condonation of delay and petitioner's exemption under Section 10(26) of Income Tax Act, 1961. HC directed CIT(Appeals) to expeditiously consider and dispose of appeals within four weeks, maintaining interim protection against coercive action. If appeals remain undecided within stipulated timeframe, respondents must issue instructions to de-freeze petitioner's bank accounts, ensuring continued operation of interim orders until final disposal.
HC disposed of writ petitions filed by a Khasi Scheduled Tribe member seeking stay of recovery proceedings under Section 156 and directions against freezing bank accounts or attachment of assets pending appeals under Section 246A. Despite settled law prohibiting pursuit of dual remedies for the same matter, HC entertained petitions considering pending appeals awaiting condonation of delay and petitioner's exemption under Section 10(26) of Income Tax Act, 1961. HC directed CIT(Appeals) to expeditiously consider and dispose of appeals within four weeks, maintaining interim protection against coercive action. If appeals remain undecided within stipulated timeframe, respondents must issue instructions to de-freeze petitioner's bank accounts, ensuring continued operation of interim orders until final disposal.
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