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 directed the Tax Recovery Officer to vacate and release the attached property within four weeks, holding that where the highest fact-finding authority's order has attained finality and the assessee has satisfied the assessed arrears, continued attachment is impermissible. The court emphasised that Section 225(2) of the IT Act mandates the TRO to give effect to appellate or other final orders, and observed that the Revenue, if successful on any pending appeal, remains entitled to pursue recovery thereafter. Accordingly, the impugned attachment dated 15.07.2022 was ordered to be lifted forthwith, the TRO to comply within the specified period.
The HC directed the Tax Recovery Officer to vacate and release the attached property within four weeks, holding that where the highest fact-finding authority's order has attained finality and the assessee has satisfied the assessed arrears, continued attachment is impermissible. The court emphasised that Section 225(2) of the IT Act mandates the TRO to give effect to appellate or other final orders, and observed that the Revenue, if successful on any pending appeal, remains entitled to pursue recovery thereafter. Accordingly, the impugned attachment dated 15.07.2022 was ordered to be lifted forthwith, the TRO to comply within the specified period.
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