Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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The HC quashed and set aside orders under s.201 for A.Y. 2018-19 and 2019-20, holding them unsustainable because identical issues were earlier quashed for A.Y. 2014-15 and 2016-17 and the AO (TDS) acted without jurisdiction contrary to the Tribunal's decisions; the Revenue's plea of alternate remedy was rejected. The matter is remitted to the AO (TDS) to the stage of issuance of the show-cause notice under s.201 for fresh adjudication after disposal of the pending HC appeal, with all consequential proceedings held infructuous. The Petitioner's undertaking to withdraw statutory appeals before the CIT(A) is accepted, subject to revival if this order is set aside on challenge.
The HC quashed and set aside orders under s.201 for A.Y. 2018-19 and 2019-20, holding them unsustainable because identical issues were earlier quashed for A.Y. 2014-15 and 2016-17 and the AO (TDS) acted without jurisdiction contrary to the Tribunal's decisions; the Revenue's plea of alternate remedy was rejected. The matter is remitted to the AO (TDS) to the stage of issuance of the show-cause notice under s.201 for fresh adjudication after disposal of the pending HC appeal, with all consequential proceedings held infructuous. The Petitioner's undertaking to withdraw statutory appeals before the CIT(A) is accepted, subject to revival if this order is set aside on challenge.
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