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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ITAT dismisses the assessee's challenges to the PCIT's exercise of jurisdiction under s.263 and upholds the show-cause notice; grounds 1-3 are rejected. The Tribunal finds a direct connection between the recorded reasons and the sale of immovable property, concluding the AO ought to have examined the transaction, cost of acquisition, any prior capital gains adjustments and the assessee's claim under s.54F. ITAT holds the assessment order for A.Y. 2015-16 passed u/s.147 read with s.144B is erroneous and prejudicial to revenue, and confirms PCIT's action setting aside the matter to the file of the AO for fresh enquiry and determination of the s.54F claim.
ITAT dismisses the assessee's challenges to the PCIT's exercise of jurisdiction under s.263 and upholds the show-cause notice; grounds 1-3 are rejected. The Tribunal finds a direct connection between the recorded reasons and the sale of immovable property, concluding the AO ought to have examined the transaction, cost of acquisition, any prior capital gains adjustments and the assessee's claim under s.54F. ITAT holds the assessment order for A.Y. 2015-16 passed u/s.147 read with s.144B is erroneous and prejudicial to revenue, and confirms PCIT's action setting aside the matter to the file of the AO for fresh enquiry and determination of the s.54F claim.
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