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 upheld the transfer order under Section 127 from Hyderabad to Delhi, rejecting petitioners' challenges. The court held that Section 127(1) requires only a reasonable opportunity to be heard, not necessarily a personal hearing, and such opportunity was duly provided and responded to by petitioners. The transfer proposal by the Chief Commissioner and acceptance by the Principal Commissioner, despite differing ranks, complied with statutory requirements. The transfer was justified by incriminating material uncovered during search and seizure operations, warranting coordinated investigation and administrative convenience per CBDT guidelines. No procedural violations or lack of sufficient reasons were found, and the petitioners failed to establish grounds for interference with the impugned transfer order.
The HC upheld the transfer order under Section 127 from Hyderabad to Delhi, rejecting petitioners' challenges. The court held that Section 127(1) requires only a reasonable opportunity to be heard, not necessarily a personal hearing, and such opportunity was duly provided and responded to by petitioners. The transfer proposal by the Chief Commissioner and acceptance by the Principal Commissioner, despite differing ranks, complied with statutory requirements. The transfer was justified by incriminating material uncovered during search and seizure operations, warranting coordinated investigation and administrative convenience per CBDT guidelines. No procedural violations or lack of sufficient reasons were found, and the petitioners failed to establish grounds for interference with the impugned transfer order.
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