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 quashed the impugned reopening assessments for AY 2016-17 and 2017-18, holding that respondent(s) failed to disclose reasons for reopening and issued final assessment orders without providing a draft assessment order, thereby violating principles of natural justice and established judicial precedent. For AY 2018-19, the HC quashed the order passed under s.148A(d) and the notice under s.148, finding denial of opportunity to seek adjournment and breach of s.148A(c). The matter is remitted to the AO to afford the petitioner an opportunity to file a reply to the s.148A(b) notice and thereafter pass a fresh s.148A(d) order in accordance with law, preferably within 12 weeks.
The HC quashed the impugned reopening assessments for AY 2016-17 and 2017-18, holding that respondent(s) failed to disclose reasons for reopening and issued final assessment orders without providing a draft assessment order, thereby violating principles of natural justice and established judicial precedent. For AY 2018-19, the HC quashed the order passed under s.148A(d) and the notice under s.148, finding denial of opportunity to seek adjournment and breach of s.148A(c). The matter is remitted to the AO to afford the petitioner an opportunity to file a reply to the s.148A(b) notice and thereafter pass a fresh s.148A(d) order in accordance with law, preferably within 12 weeks.
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