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 held that the transfer of the assessment case between Assessing Officers (AOs) under section 127 was not valid as no formal order under section 127 was passed, nor was the assessee given an opportunity to be heard or reasons recorded. The AO who completed the assessment assumed jurisdiction without proper authority, as the procedural requirements for transfer of jurisdiction were not complied with. Consequently, the order passed by the AO lacking jurisdiction was quashed. The appeal filed by the assessee was allowed, affirming that jurisdiction cannot be assumed without a valid transfer order under section 127.
The ITAT held that the transfer of the assessment case between Assessing Officers (AOs) under section 127 was not valid as no formal order under section 127 was passed, nor was the assessee given an opportunity to be heard or reasons recorded. The AO who completed the assessment assumed jurisdiction without proper authority, as the procedural requirements for transfer of jurisdiction were not complied with. Consequently, the order passed by the AO lacking jurisdiction was quashed. The appeal filed by the assessee was allowed, affirming that jurisdiction cannot be assumed without a valid transfer order under section 127.
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