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 quashed assessment order dated 11.10.2022 for non-compliance with Standard Operating Procedure under Faceless Assessment provisions u/s 144B. Court held that when assessee remains non-responsive to notice u/s 142(1), revenue authorities are mandatorily required to send physical communication via speed-post to latest known address as per SOP. Respondent's contention that prior non-responsiveness eliminated need for physical communication was rejected. Court emphasized mandatory nature of SOP requirements regardless of stage of proceedings. Matter remanded to Faceless Assessment Authority with directions to comply with SOP dated 3.8.2022 and pass fresh order following prescribed procedure.
HC quashed assessment order dated 11.10.2022 for non-compliance with Standard Operating Procedure under Faceless Assessment provisions u/s 144B. Court held that when assessee remains non-responsive to notice u/s 142(1), revenue authorities are mandatorily required to send physical communication via speed-post to latest known address as per SOP. Respondent's contention that prior non-responsiveness eliminated need for physical communication was rejected. Court emphasized mandatory nature of SOP requirements regardless of stage of proceedings. Matter remanded to Faceless Assessment Authority with directions to comply with SOP dated 3.8.2022 and pass fresh order following prescribed procedure.
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