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 allowed the writ petition and quashed the assessment order issued under s.144C for failure to consider the assessee's objections submitted to the DRP; the court held that non-communication to the AO does not negate objections filed before the DRP and the AO should have awaited the DRP's decision. The HC directed the Chief Commissioner (International Taxation) to devise and implement a mechanism to ensure DRP-filed objections are communicated to the AO to prevent premature orders, and ordered the Chief Commissioner to file an affidavit detailing the proposed system within four weeks. The impugned orders stand set aside.
The HC allowed the writ petition and quashed the assessment order issued under s.144C for failure to consider the assessee's objections submitted to the DRP; the court held that non-communication to the AO does not negate objections filed before the DRP and the AO should have awaited the DRP's decision. The HC directed the Chief Commissioner (International Taxation) to devise and implement a mechanism to ensure DRP-filed objections are communicated to the AO to prevent premature orders, and ordered the Chief Commissioner to file an affidavit detailing the proposed system within four weeks. The impugned orders stand set aside.
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