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 held that the assessment framed by ITO Ward 9(4), Kolkata is nullity for want of jurisdiction where notice under s.143(2) was issued by ITO Ward 10(2), Kolkata but the jurisdictional AO (Ward 9(4)) proceeded to frame assessment without issuance of a fresh statutory s.143(2) notice. The Tribunal concluded that issuance of the statutory s.143(2) notice is a precondition to confer jurisdiction on the AO; absent such notice the assessment cannot be sustained. The appeal by the taxpayer was allowed and the assessment framed by ITO Ward 9(4) was set aside.
ITAT held that the assessment framed by ITO Ward 9(4), Kolkata is nullity for want of jurisdiction where notice under s.143(2) was issued by ITO Ward 10(2), Kolkata but the jurisdictional AO (Ward 9(4)) proceeded to frame assessment without issuance of a fresh statutory s.143(2) notice. The Tribunal concluded that issuance of the statutory s.143(2) notice is a precondition to confer jurisdiction on the AO; absent such notice the assessment cannot be sustained. The appeal by the taxpayer was allowed and the assessment framed by ITO Ward 9(4) was set aside.
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