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 dismissed the petitioner's challenge to a reopening notice under section 148 of the Income Tax Act. The petitioner sold immovable property for Rs. 40 lakh to a third party through consent terms with a lender to satisfy debt, but failed to file any return of income disclosing this transaction. The petitioner argued denial of hearing opportunity under section 144B(6)(vii), violating natural justice principles. The HC held that since no return was filed, no hearing opportunity was required. The court found clear income escapement causing revenue loss and directed compliance with the impugned notice, rejecting the petition entirely.
The HC dismissed the petitioner's challenge to a reopening notice under section 148 of the Income Tax Act. The petitioner sold immovable property for Rs. 40 lakh to a third party through consent terms with a lender to satisfy debt, but failed to file any return of income disclosing this transaction. The petitioner argued denial of hearing opportunity under section 144B(6)(vii), violating natural justice principles. The HC held that since no return was filed, no hearing opportunity was required. The court found clear income escapement causing revenue loss and directed compliance with the impugned notice, rejecting the petition entirely.
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