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 set aside the order and notice dated 30.06.2025 and remitted the matter to the AO for fresh consideration. The petitioner, having undertaken not to contend that the order under s.148A(3) is time-barred and not to challenge the legality of the notice under s.148A(1), relinquished those pleas. The AO is directed to examine the documents identified by the parties and any other material he considers necessary, to afford the petitioner prior notice with reasonable time to furnish further documents or replies, and thereafter to pass a reasoned, speaking order under the relevant provisions, applying s.149(1)(b) as appropriate.
The HC set aside the order and notice dated 30.06.2025 and remitted the matter to the AO for fresh consideration. The petitioner, having undertaken not to contend that the order under s.148A(3) is time-barred and not to challenge the legality of the notice under s.148A(1), relinquished those pleas. The AO is directed to examine the documents identified by the parties and any other material he considers necessary, to afford the petitioner prior notice with reasonable time to furnish further documents or replies, and thereafter to pass a reasoned, speaking order under the relevant provisions, applying s.149(1)(b) as appropriate.
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