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 held that its earlier order setting aside assessments on the amalgamating, non-existent company did not contain any "finding" or "direction" within the meaning of s.153(6) of the Act. The prior order merely applied the ratio of Maruti Suzuki to quash assessments on a non-existent entity and clarified that fresh proceedings, if any, could be initiated against the amalgamated transferee in accordance with law, which did not amount to a binding direction. Consequently, the extended limitation under s.153(6) was inapplicable. The impugned assessment framed against the transferee company for A.Y. 2007-08 was therefore held to be time-barred under s.153(1), and stood quashed, with the Revenue's contentions rejected.
HC held that its earlier order setting aside assessments on the amalgamating, non-existent company did not contain any "finding" or "direction" within the meaning of s.153(6) of the Act. The prior order merely applied the ratio of Maruti Suzuki to quash assessments on a non-existent entity and clarified that fresh proceedings, if any, could be initiated against the amalgamated transferee in accordance with law, which did not amount to a binding direction. Consequently, the extended limitation under s.153(6) was inapplicable. The impugned assessment framed against the transferee company for A.Y. 2007-08 was therefore held to be time-barred under s.153(1), and stood quashed, with the Revenue's contentions rejected.
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