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 held that notices and the order issued under the surrendered PAN were invalid where the petitioner had surrendered its earlier PAN and filed the return for AY 2019-20 under a newly allotted PAN; the formal notice under the old PAN was communicated to the respondent's office on 14.06.2019 but proceedings continued under the surrendered PAN. Consequently, the impugned order under section 148A(d) and the notice under section 148 were quashed and set aside as issued without jurisdiction. The respondent remains at liberty to initiate fresh proceedings by issuing a valid notice under the new PAN in accordance with law.
The HC held that notices and the order issued under the surrendered PAN were invalid where the petitioner had surrendered its earlier PAN and filed the return for AY 2019-20 under a newly allotted PAN; the formal notice under the old PAN was communicated to the respondent's office on 14.06.2019 but proceedings continued under the surrendered PAN. Consequently, the impugned order under section 148A(d) and the notice under section 148 were quashed and set aside as issued without jurisdiction. The respondent remains at liberty to initiate fresh proceedings by issuing a valid notice under the new PAN in accordance with law.
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