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 and set aside the impugned assessment order premised on alleged failure to deduct TDS under s.194Q and disallowance under s.40(a)(ia), holding that the Faceless Assessment Unit issued an ILDP and passed the assessment without considering the petitioner's detailed reply dated 08.03.2025, thereby breaching principles of natural justice. The matter is remitted to the respondent Faceless Assessment Unit for a de novo assessment, directing that the petitioner's reply be considered on merits and that an opportunity of hearing be afforded as per s.144B if requested. The reassessment exercise must be completed within twelve weeks from receipt of this order.
The HC quashed and set aside the impugned assessment order premised on alleged failure to deduct TDS under s.194Q and disallowance under s.40(a)(ia), holding that the Faceless Assessment Unit issued an ILDP and passed the assessment without considering the petitioner's detailed reply dated 08.03.2025, thereby breaching principles of natural justice. The matter is remitted to the respondent Faceless Assessment Unit for a de novo assessment, directing that the petitioner's reply be considered on merits and that an opportunity of hearing be afforded as per s.144B if requested. The reassessment exercise must be completed within twelve weeks from receipt of this order.
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