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 ITAT set aside the assessment framed under section 153C, holding that the combined satisfaction note issued by the AO for multiple assessment years was invalid. The AO initiated proceedings based on documents seized during a search in a third-party case, but the issuance of a consolidated satisfaction note for different years contravened the statutory requirement to record separate satisfaction notes for each assessment year. Consequently, the CIT(A) rightly deleted the addition of Rs. 2,11,00,000, and the ITAT allowed the assessee's appeal, quashing the assessment proceedings initiated on the basis of the flawed combined satisfaction note.
The ITAT set aside the assessment framed under section 153C, holding that the combined satisfaction note issued by the AO for multiple assessment years was invalid. The AO initiated proceedings based on documents seized during a search in a third-party case, but the issuance of a consolidated satisfaction note for different years contravened the statutory requirement to record separate satisfaction notes for each assessment year. Consequently, the CIT(A) rightly deleted the addition of Rs. 2,11,00,000, and the ITAT allowed the assessee's appeal, quashing the assessment proceedings initiated on the basis of the flawed combined satisfaction note.
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