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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ITAT set aside CIT(A)'s order passed against deceased assessee where proceedings continued without involving legal representatives. CIT(A) issued four notices after assessee's death despite AO being informed of death through letter dated 18.6.2018 with death certificate and will. CIT(A) passed order on 8.6.2023 in name of assessee who died on 8.9.2018, rendering order unsustainable. Legal representatives were denied opportunity to present case before CIT(A). ITAT admitted additional evidence under Rule 29 including bank statements, sale deeds, and will copies. Matter remanded to CIT(A) with directions to consider additional evidence and decide afresh after providing reasonable hearing opportunity to legal representatives. Appeal allowed for statistical purposes.
ITAT set aside CIT(A)'s order passed against deceased assessee where proceedings continued without involving legal representatives. CIT(A) issued four notices after assessee's death despite AO being informed of death through letter dated 18.6.2018 with death certificate and will. CIT(A) passed order on 8.6.2023 in name of assessee who died on 8.9.2018, rendering order unsustainable. Legal representatives were denied opportunity to present case before CIT(A). ITAT admitted additional evidence under Rule 29 including bank statements, sale deeds, and will copies. Matter remanded to CIT(A) with directions to consider additional evidence and decide afresh after providing reasonable hearing opportunity to legal representatives. Appeal allowed for statistical purposes.
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