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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HC held the impugned notice dated 06.11.2020 to be barred by limitation and quashed it, ruling for the respondent-assessee. The court construed s.153(7) (as amended by the Finance Act, 2016) together with s.153(9), and, invoking the legislative Memorandum to the Finance Act, concluded the extended time-limit for cases pending on 01.06.2016 expired on 31.03.2017; consequently the assessment pursuant to the Tribunal's directions was required to be completed by that date. The Revenue's reliance on s.153(3)(ii) to give effect to the Tribunal's direction at any time was rejected as untenable. Decision therefore in favour of the assessee.
HC held the impugned notice dated 06.11.2020 to be barred by limitation and quashed it, ruling for the respondent-assessee. The court construed s.153(7) (as amended by the Finance Act, 2016) together with s.153(9), and, invoking the legislative Memorandum to the Finance Act, concluded the extended time-limit for cases pending on 01.06.2016 expired on 31.03.2017; consequently the assessment pursuant to the Tribunal's directions was required to be completed by that date. The Revenue's reliance on s.153(3)(ii) to give effect to the Tribunal's direction at any time was rejected as untenable. Decision therefore in favour of the assessee.
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