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 Central Board of Direct Taxes issued guidelines establishing compulsory selection parameters for complete scrutiny during FY 2025-26. Six specific categories mandate scrutiny: cases involving surveys under section 133A conducted after 01.04.2023; search and seizure operations under sections 132/132A during specified periods; entities claiming tax exemptions without valid registrations under sections 12A, 12AB, or 35; cases with recurring additions exceeding prescribed thresholds that became final or were upheld on appeal; and cases with specific tax evasion information from law enforcement agencies. The directive requires notice under section 143(2) by 30.06.2025, mandates transfer of non-central charge cases within fifteen days, and establishes procedural requirements for jurisdictional assessing officers and the National Faceless Assessment Centre for case processing and documentation.
The Central Board of Direct Taxes issued guidelines establishing compulsory selection parameters for complete scrutiny during FY 2025-26. Six specific categories mandate scrutiny: cases involving surveys under section 133A conducted after 01.04.2023; search and seizure operations under sections 132/132A during specified periods; entities claiming tax exemptions without valid registrations under sections 12A, 12AB, or 35; cases with recurring additions exceeding prescribed thresholds that became final or were upheld on appeal; and cases with specific tax evasion information from law enforcement agencies. The directive requires notice under section 143(2) by 30.06.2025, mandates transfer of non-central charge cases within fifteen days, and establishes procedural requirements for jurisdictional assessing officers and the National Faceless Assessment Centre for case processing and documentation.
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