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 dismissed writ petition challenging reopening of assessment under section 147, where petitioner failed to respond to show-cause notices issued under section 148A regarding undisclosed materials and transactions. Court held that since petitioner received departmental notice but chose not to contest before Competent Authority and final assessment order was already passed, it was inappropriate to invoke writ jurisdiction under Article 226. HC determined that grounds raised could be addressed before Appellate Authority in accordance with law. Decision aligned with previous ruling involving same petitioner for different assessment year, where statutory remedies were deemed adequate. Writ petition dismissed with direction to pursue available appellate remedies under the Act.
HC dismissed writ petition challenging reopening of assessment under section 147, where petitioner failed to respond to show-cause notices issued under section 148A regarding undisclosed materials and transactions. Court held that since petitioner received departmental notice but chose not to contest before Competent Authority and final assessment order was already passed, it was inappropriate to invoke writ jurisdiction under Article 226. HC determined that grounds raised could be addressed before Appellate Authority in accordance with law. Decision aligned with previous ruling involving same petitioner for different assessment year, where statutory remedies were deemed adequate. Writ petition dismissed with direction to pursue available appellate remedies under the Act.
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