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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The HC allowed the writ petition challenging reassessment notices issued under sections 148A and 148 of the Income Tax Act. The petitioner contended that notices issued by the jurisdictional Assessing Officer should have been processed in a faceless manner as mandated by the Finance Act 2021. The HC followed its earlier precedent in Kankanala Ravindra Reddy, which held that proceedings under sections 148A and 148 conducted in non-faceless manner violated section 151A read with Notification 18/2022. The court quashed the impugned notices, noting that despite 16 months since the precedent judgment, the Income Tax Department continued issuing similar notices contravening statutory amendments. The relief granted remains subject to the outcome of the pending Supreme Court appeal against the Kankanala Ravindra Reddy decision.
The HC allowed the writ petition challenging reassessment notices issued under sections 148A and 148 of the Income Tax Act. The petitioner contended that notices issued by the jurisdictional Assessing Officer should have been processed in a faceless manner as mandated by the Finance Act 2021. The HC followed its earlier precedent in Kankanala Ravindra Reddy, which held that proceedings under sections 148A and 148 conducted in non-faceless manner violated section 151A read with Notification 18/2022. The court quashed the impugned notices, noting that despite 16 months since the precedent judgment, the Income Tax Department continued issuing similar notices contravening statutory amendments. The relief granted remains subject to the outcome of the pending Supreme Court appeal against the Kankanala Ravindra Reddy decision.
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