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" ?
The HC held that reassessment proceedings cannot proceed under the unamended s.148 of the I.T. Act when a notice was digitally signed on 1.4.2021; such notice must be treated as issued under substituted s.148A and as a show-cause notice under s.148A(b). The AO is directed to furnish within 30 days the information/material relied upon; the petitioner may reply within two weeks. The requirement of prior approval under s.148A(a) is dispensed with as a one-time measure for notices issued from 01.04.2021. The AO shall pass an order under s.148A(d) and may thereafter follow s.148A procedure before issuing a substituted s.148 notice. All statutory and other defences, including under s.149, are preserved. The impugned assessment order is quashed and set aside.
The HC held that reassessment proceedings cannot proceed under the unamended s.148 of the I.T. Act when a notice was digitally signed on 1.4.2021; such notice must be treated as issued under substituted s.148A and as a show-cause notice under s.148A(b). The AO is directed to furnish within 30 days the information/material relied upon; the petitioner may reply within two weeks. The requirement of prior approval under s.148A(a) is dispensed with as a one-time measure for notices issued from 01.04.2021. The AO shall pass an order under s.148A(d) and may thereafter follow s.148A procedure before issuing a substituted s.148 notice. All statutory and other defences, including under s.149, are preserved. The impugned assessment order is quashed and set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
