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 held that writ petitions are disposed and directed procedural safeguards before initiation of reassessment under s.147/148A: the assessees must file their returns by 31.10.2025; within one week of filing the AO shall disclose by email the information relied upon to propose reassessment; assessees shall have two weeks to file objections by a prescribed/accessible mode; the AO shall pass a reasoned, speaking order on those objections within two further weeks and communicate it to the assessees; if reassessment is to be initiated, the first hearing date shall be fixed with at least 30 days' advance notice. The HC reaffirmed that precedential law and Article 141 mandate affording a minimal opportunity to object before reassessment is initiated.
HC held that writ petitions are disposed and directed procedural safeguards before initiation of reassessment under s.147/148A: the assessees must file their returns by 31.10.2025; within one week of filing the AO shall disclose by email the information relied upon to propose reassessment; assessees shall have two weeks to file objections by a prescribed/accessible mode; the AO shall pass a reasoned, speaking order on those objections within two further weeks and communicate it to the assessees; if reassessment is to be initiated, the first hearing date shall be fixed with at least 30 days' advance notice. The HC reaffirmed that precedential law and Article 141 mandate affording a minimal opportunity to object before reassessment is initiated.
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