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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
HC set aside notice u/s 148 and remanded matter to assessing officer for fresh decision. Court held that procedural safeguards u/s 148A require meaningful opportunity of hearing, not mere formality. Assessing officer violated principles of natural justice by rejecting petitioner's response without providing adequate reasons or substantiating why audited accounts were unacceptable despite credible information from high risk transactions module indicating escaped assessment. Court emphasized that when rejecting assessee's contentions, appropriate reasons must be provided explaining why response is unacceptable. Notice and impugned order cannot be sustained without compliance with mandatory procedural requirements ensuring effective hearing opportunity.
HC set aside notice u/s 148 and remanded matter to assessing officer for fresh decision. Court held that procedural safeguards u/s 148A require meaningful opportunity of hearing, not mere formality. Assessing officer violated principles of natural justice by rejecting petitioner's response without providing adequate reasons or substantiating why audited accounts were unacceptable despite credible information from high risk transactions module indicating escaped assessment. Court emphasized that when rejecting assessee's contentions, appropriate reasons must be provided explaining why response is unacceptable. Notice and impugned order cannot be sustained without compliance with mandatory procedural requirements ensuring effective hearing opportunity.
Note: It is a system-generated summary and is for quick reference only.