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 upheld the validity of reassessment proceedings initiated under Section 148 of the Act by the Jurisdictional Assessing Officer, holding that both JAO and FAO possess concurrent jurisdiction under the statutory scheme, including Section 151A and the 2022 e-assessment scheme. The HC reaffirmed its earlier ruling in TKS Builders as binding within its territorial jurisdiction, noting that the SC's dismissal of an SLP against a contrary Bombay HC decision, without a reasoned order, does not impliedly overrule or dilute TKS Builders. Pending appeals before the SC were held not to affect the precedential authority of TKS Builders. Consequently, all writ petitions challenging jurisdiction and reopening were dismissed, with no relief granted to the petitioners.
The HC upheld the validity of reassessment proceedings initiated under Section 148 of the Act by the Jurisdictional Assessing Officer, holding that both JAO and FAO possess concurrent jurisdiction under the statutory scheme, including Section 151A and the 2022 e-assessment scheme. The HC reaffirmed its earlier ruling in TKS Builders as binding within its territorial jurisdiction, noting that the SC's dismissal of an SLP against a contrary Bombay HC decision, without a reasoned order, does not impliedly overrule or dilute TKS Builders. Pending appeals before the SC were held not to affect the precedential authority of TKS Builders. Consequently, all writ petitions challenging jurisdiction and reopening were dismissed, with no relief granted to the petitioners.
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