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 set aside the impugned order and remanded the matter to the assessing authority for fresh adjudication under the amended Section 148A (effective 1 Sept 2024), in light of the GST order dated 11 July 2025. The Court observed the earlier assessment could not have taken the subsequent GST closure into account and that the GST closure bears materially on the Section 148A proceedings. The petitioner is permitted to file the GST order with the Assistant Commissioner of Income Tax, Circle-25(1), accompanied by a concise note of submissions within four weeks. The challenge to the validity of the initiation notice was left open for determination at a later stage if necessary.
HC set aside the impugned order and remanded the matter to the assessing authority for fresh adjudication under the amended Section 148A (effective 1 Sept 2024), in light of the GST order dated 11 July 2025. The Court observed the earlier assessment could not have taken the subsequent GST closure into account and that the GST closure bears materially on the Section 148A proceedings. The petitioner is permitted to file the GST order with the Assistant Commissioner of Income Tax, Circle-25(1), accompanied by a concise note of submissions within four weeks. The challenge to the validity of the initiation notice was left open for determination at a later stage if necessary.
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