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 review petition challenging the quashing of criminal proceedings under Section 276CC related to the non-filing of income tax returns for AY 2012-2013. The petitioner had filed a revised return, and penalty proceedings were dropped, resulting in an ordered refund. The Court found no error apparent in the prior order quashing the criminal case, deeming continuation of proceedings unnecessary. Consequently, the criminal proceedings against the appellant under Section 276CC remain quashed, and the review petition was dismissed.
The SC dismissed the review petition challenging the quashing of criminal proceedings under Section 276CC related to the non-filing of income tax returns for AY 2012-2013. The petitioner had filed a revised return, and penalty proceedings were dropped, resulting in an ordered refund. The Court found no error apparent in the prior order quashing the criminal case, deeming continuation of proceedings unnecessary. Consequently, the criminal proceedings against the appellant under Section 276CC remain quashed, and the review petition was dismissed.
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