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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ITAT allowed the appeal and quashed the intimation under s. 143(1) issued by the DDIT, CPC, Bengaluru. The Tribunal found the intimation invalid as the Revenue issued a query on 26/12/2023 giving the assessee 30 days to respond but passed the s. 143(1) intimation on 29/12/2023 after only two days, treating gross receipts as taxable income and disallowing claimed exemption under s. 10(23C)(iiiac). The Tribunal held this denial of the statutory 30-day response period violated principles of natural justice and constituted a jurisdictional defect, rendering the intimation vitiated in law.
ITAT allowed the appeal and quashed the intimation under s. 143(1) issued by the DDIT, CPC, Bengaluru. The Tribunal found the intimation invalid as the Revenue issued a query on 26/12/2023 giving the assessee 30 days to respond but passed the s. 143(1) intimation on 29/12/2023 after only two days, treating gross receipts as taxable income and disallowing claimed exemption under s. 10(23C)(iiiac). The Tribunal held this denial of the statutory 30-day response period violated principles of natural justice and constituted a jurisdictional defect, rendering the intimation vitiated in law.
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