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 upheld the Section 127 transfer of the assessee's file from Panchkula to Central Circle-II, Chandigarh as a valid administrative action taken in furtherance of administrative exigency; the transfer was preceded by opportunity of hearing and recorded the representative's no-objection, which was not specifically impugned. The Court held that such an exercise of power is amenable to challenge only on grounds of mala fides or absence of public/revenue interest, and cannot be indirectly attacked after failure to contest the transfer earlier. Notices issued under Sections 142 and 148 were held not liable to be quashed on account of the transfer, and the transfer remains valid even if related search and seizure proceedings are quashed.
HC upheld the Section 127 transfer of the assessee's file from Panchkula to Central Circle-II, Chandigarh as a valid administrative action taken in furtherance of administrative exigency; the transfer was preceded by opportunity of hearing and recorded the representative's no-objection, which was not specifically impugned. The Court held that such an exercise of power is amenable to challenge only on grounds of mala fides or absence of public/revenue interest, and cannot be indirectly attacked after failure to contest the transfer earlier. Notices issued under Sections 142 and 148 were held not liable to be quashed on account of the transfer, and the transfer remains valid even if related search and seizure proceedings are quashed.
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