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 SC dismissed the petition seeking condonation of a 196-day delay in filing the SLP, finding no sufficient grounds to excuse the delay. The petitioner's challenge pertained to the reopening of assessment under section 147 based on alleged undisclosed income from trading in Kusha Script on BSE. The AO's reasons recorded lacked detailed information beyond the non-genuine gain assertion. The Court noted that even if the proposed addition was accepted, the income taxed under section 115JB would eliminate any further taxable income, rendering reassessment futile. Consequently, the petition was dismissed on delay grounds, and the reassessment proceedings were effectively quashed as continuing them would serve no useful purpose.
The SC dismissed the petition seeking condonation of a 196-day delay in filing the SLP, finding no sufficient grounds to excuse the delay. The petitioner's challenge pertained to the reopening of assessment under section 147 based on alleged undisclosed income from trading in Kusha Script on BSE. The AO's reasons recorded lacked detailed information beyond the non-genuine gain assertion. The Court noted that even if the proposed addition was accepted, the income taxed under section 115JB would eliminate any further taxable income, rendering reassessment futile. Consequently, the petition was dismissed on delay grounds, and the reassessment proceedings were effectively quashed as continuing them would serve no useful purpose.
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