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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ITAT dismissed the appeal, holding that transfer of the file under s.127 to another AO within the same city did not obligate re-issuance of notice or a fresh hearing and that the successor AO validly assumed jurisdiction to reopen and frame assessment under s.147 without re-issuing notice under s.143(2). The reopening and addition for undeclared capital gains on sale of immovable property were sustained on available information and consistent treatment of co-owners; the assessee's belated factual plea for indexed cost of acquisition was not admitted for lack of evidence and undue delay. Result: appeal dismissed and assessment upheld.
ITAT dismissed the appeal, holding that transfer of the file under s.127 to another AO within the same city did not obligate re-issuance of notice or a fresh hearing and that the successor AO validly assumed jurisdiction to reopen and frame assessment under s.147 without re-issuing notice under s.143(2). The reopening and addition for undeclared capital gains on sale of immovable property were sustained on available information and consistent treatment of co-owners; the assessee's belated factual plea for indexed cost of acquisition was not admitted for lack of evidence and undue delay. Result: appeal dismissed and assessment upheld.
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