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 set aside the impugned assessment order and remitted the matter for fresh adjudication. The petitioner, a customs house agent, had claimed reimbursable expenses but failed to produce documentary evidence substantiating non-liability to deduct tax at source; the assessing and revisional authorities accordingly disallowed the claim. In the interest of justice the HC granted the petitioner another opportunity to place documentary proof before the assessing officer. The HC directed the assessing officer to consider the newly produced evidence and to pass fresh orders in accordance with law. The remand disposes of the petition without deciding the substantive tax merits.
The HC set aside the impugned assessment order and remitted the matter for fresh adjudication. The petitioner, a customs house agent, had claimed reimbursable expenses but failed to produce documentary evidence substantiating non-liability to deduct tax at source; the assessing and revisional authorities accordingly disallowed the claim. In the interest of justice the HC granted the petitioner another opportunity to place documentary proof before the assessing officer. The HC directed the assessing officer to consider the newly produced evidence and to pass fresh orders in accordance with law. The remand disposes of the petition without deciding the substantive tax merits.
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