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 that the respondent erred in computing the period of limitation from the date of the order under s.143(3); the matter sought to be revised before the respondent concerned the rejection of the appellants' rectification application decided on 9 Feb 2024, and the s.264 revision filed on 14 Jan 2025 fell within the one-year limitation prescribed by s.264. The respondent's conclusion that the revision was time-barred was unsustainable. The impugned order is quashed and set aside, and the matter is remanded to the respondent to adjudicate the appellants' s.264 revision application on merits and in accordance with law.
HC held that the respondent erred in computing the period of limitation from the date of the order under s.143(3); the matter sought to be revised before the respondent concerned the rejection of the appellants' rectification application decided on 9 Feb 2024, and the s.264 revision filed on 14 Jan 2025 fell within the one-year limitation prescribed by s.264. The respondent's conclusion that the revision was time-barred was unsustainable. The impugned order is quashed and set aside, and the matter is remanded to the respondent to adjudicate the appellants' s.264 revision application on merits and in accordance with law.
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