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 order and remanded the matter to the respondent for fresh consideration, holding that digital marketing constitutes a business (not a profession) for purposes of Section 44AB. The court found the petitioner's turnover is below Rs. 5 crore and cash receipts and payments are each below five percent of turnover, with transactional evidence showing bank-mediated operations; therefore the petitioner falls within the proviso exemption to Section 44AB(a). The respondent's prior conclusion characterizing the activity as a profession was the product of non-application of mind. The petitioner is directed to file a reply with supporting documents within two weeks of service of this order.
The HC set aside the impugned order and remanded the matter to the respondent for fresh consideration, holding that digital marketing constitutes a business (not a profession) for purposes of Section 44AB. The court found the petitioner's turnover is below Rs. 5 crore and cash receipts and payments are each below five percent of turnover, with transactional evidence showing bank-mediated operations; therefore the petitioner falls within the proviso exemption to Section 44AB(a). The respondent's prior conclusion characterizing the activity as a profession was the product of non-application of mind. The petitioner is directed to file a reply with supporting documents within two weeks of service of this order.
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