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...
Page of 4827
Press 'Enter' after typing page number.
141 to 160 of 96536 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
AT dismissed both appeals and upheld the impugned provisional attachment and adjudication orders under the PBPTA. The Tribunal found the Approving Authority applied independent mind, relied on inquiry materials and notes, and concluded the references and orders were within the one-year limitation under s.26(7). The Appellant failed to discharge the evidential burden to prove legitimate consideration for two properties; cash payments and unexplained bank deposits, absence of corroborative agricultural income and missing ITRs warranted inference of non-agricultural/benami dealings. Alleged procedural flaws were characterized as mere surmises. Consequently, the PAO and consequent adjudication were sustained and both appeals were dismissed.
AT dismissed both appeals and upheld the impugned provisional attachment and adjudication orders under the PBPTA. The Tribunal found the Approving Authority applied independent mind, relied on inquiry materials and notes, and concluded the references and orders were within the one-year limitation under s.26(7). The Appellant failed to discharge the evidential burden to prove legitimate consideration for two properties; cash payments and unexplained bank deposits, absence of corroborative agricultural income and missing ITRs warranted inference of non-agricultural/benami dealings. Alleged procedural flaws were characterized as mere surmises. Consequently, the PAO and consequent adjudication were sustained and both appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.