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 dismissed the petitioner's writ insofar as it sought premature interference with the respondent's tax notice, holding that the petitioner failed to file the requisite reply to the impugned notice dated 18.03.2025 and thus cannot seek relief before the Court without exhausting the statutory process. The Court found that the petitioner bears the evidentiary burden to substantiate entitlement to the lower TDS rate where the seller's PAN was not linked to Aadhaar at the relevant time. The HC directed the Petitioner to file a substantive reply with supporting documents within two weeks of receipt of this order, and directed the Respondent to consider that reply and pass a decision expeditiously.
The HC dismissed the petitioner's writ insofar as it sought premature interference with the respondent's tax notice, holding that the petitioner failed to file the requisite reply to the impugned notice dated 18.03.2025 and thus cannot seek relief before the Court without exhausting the statutory process. The Court found that the petitioner bears the evidentiary burden to substantiate entitlement to the lower TDS rate where the seller's PAN was not linked to Aadhaar at the relevant time. The HC directed the Petitioner to file a substantive reply with supporting documents within two weeks of receipt of this order, and directed the Respondent to consider that reply and pass a decision expeditiously.
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