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 rejected the revision petition under section 264, noting the petitioner failed to file a reply or submit documentary evidence before the AO. The petitioner's non-participation was attributed to a change in management and notices being served under the old PAN, causing lack of awareness. The Court held that non-participation alone does not bar prosecution under section 264. Given the petitioner's society converted from a Trust to a Society, resulting in management difficulties, the HC exercised discretion in the interest of justice. The impugned order under section 264 and the best judgment assessment order under section 147 were set aside. The matter was remanded to the AO for fresh consideration, thereby granting the petitioner an opportunity to present the case afresh.
The HC rejected the revision petition under section 264, noting the petitioner failed to file a reply or submit documentary evidence before the AO. The petitioner's non-participation was attributed to a change in management and notices being served under the old PAN, causing lack of awareness. The Court held that non-participation alone does not bar prosecution under section 264. Given the petitioner's society converted from a Trust to a Society, resulting in management difficulties, the HC exercised discretion in the interest of justice. The impugned order under section 264 and the best judgment assessment order under section 147 were set aside. The matter was remanded to the AO for fresh consideration, thereby granting the petitioner an opportunity to present the case afresh.
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