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 found that statutory respondents, including the Income Tax Department, failed to discharge their duties by not initiating criminal proceedings or filing an FIR despite clear evidence of identity theft involving misuse of the petitioner's PAN and Aadhaar details. Respondent No. 6 breached its obligations under the Master Directions - KYC Direction 2016 and Aadhaar Authentication Regulations by failing to authenticate the petitioner's Aadhaar at account opening, contributing to the fraud. The court condemned the respondents' prolonged inaction and directed Respondent No. 1 to enhance public awareness and ensure compliance with Aadhaar authentication protocols. The petitioner was instructed to seek guidance from the Income Tax Authorities regarding issuance or deactivation of the compromised PAN. The attachment order issued by Respondent No. 7 for recovery of dues linked to fraudulent transactions was quashed. The petition was accordingly disposed of.
The HC found that statutory respondents, including the Income Tax Department, failed to discharge their duties by not initiating criminal proceedings or filing an FIR despite clear evidence of identity theft involving misuse of the petitioner's PAN and Aadhaar details. Respondent No. 6 breached its obligations under the Master Directions - KYC Direction 2016 and Aadhaar Authentication Regulations by failing to authenticate the petitioner's Aadhaar at account opening, contributing to the fraud. The court condemned the respondents' prolonged inaction and directed Respondent No. 1 to enhance public awareness and ensure compliance with Aadhaar authentication protocols. The petitioner was instructed to seek guidance from the Income Tax Authorities regarding issuance or deactivation of the compromised PAN. The attachment order issued by Respondent No. 7 for recovery of dues linked to fraudulent transactions was quashed. The petition was accordingly disposed of.
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