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 quashed the impugned assessment order framed by the first respondent under Section 147 read with Section 144C(3) and the order passed by the third respondent (Dispute Resolution Panel) and remitted the matters to the respondents for fresh adjudication. The court found a gross violation of principles of natural justice in the issuance and finalization of proceedings under Section 148A(d) and Section 144A(d), noting the petitioner's active cooperation, including timely responses and an objection under Section 144C(2) filed before the DRP with a copy emailed to the assessing office as required. The respondents are directed to reconsider and pass fresh orders consistent with law.
The HC quashed the impugned assessment order framed by the first respondent under Section 147 read with Section 144C(3) and the order passed by the third respondent (Dispute Resolution Panel) and remitted the matters to the respondents for fresh adjudication. The court found a gross violation of principles of natural justice in the issuance and finalization of proceedings under Section 148A(d) and Section 144A(d), noting the petitioner's active cooperation, including timely responses and an objection under Section 144C(2) filed before the DRP with a copy emailed to the assessing office as required. The respondents are directed to reconsider and pass fresh orders consistent with law.
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