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 allowed the petition and quashed the second show cause notice dated 15.09.2005, holding it void for want of jurisdiction and barred by limitation. The court reasoned that the revenue could not initiate a fresh proceeding to invoke a purportedly changed law after the Tribunal had earlier set aside the original demand arising from the SCN dated 02.04.1998, and that permitting multiple proceedings for the same alleged infringement would contravene settled tax-law principles analogous to res judicata. The HC further held that Section 11A(11)(a) imposes a requirement of reasonable time to conclude proceedings, no satisfactory explanation was offered for delay beyond six months from 19.12.2016, and reliance on the Supreme Court decision was distinguishable.
HC allowed the petition and quashed the second show cause notice dated 15.09.2005, holding it void for want of jurisdiction and barred by limitation. The court reasoned that the revenue could not initiate a fresh proceeding to invoke a purportedly changed law after the Tribunal had earlier set aside the original demand arising from the SCN dated 02.04.1998, and that permitting multiple proceedings for the same alleged infringement would contravene settled tax-law principles analogous to res judicata. The HC further held that Section 11A(11)(a) imposes a requirement of reasonable time to conclude proceedings, no satisfactory explanation was offered for delay beyond six months from 19.12.2016, and reliance on the Supreme Court decision was distinguishable.
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