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 upheld the impugned show cause notice and provisional attachment issued under s.24 of the Benami Act against A and related entities, holding that the Initiating Officer (IO) is only required to have "reason to believe" based on some material in his possession, a standard higher than under BNS/BNSS but lower than a prima facie case. HC declined to examine in writ jurisdiction whether the transactions fit the definition of "benami transaction" under s.2(9), as this falls within the domain of the Adjudicating Authority. HC held that prior written approval of the Approving Authority under s.24(3) need not be supplied with the attachment order, though it must be provided on request. Liberty was reserved to A to seek relief before the Adjudicating Authority. The writ petition was dismissed.
HC upheld the impugned show cause notice and provisional attachment issued under s.24 of the Benami Act against A and related entities, holding that the Initiating Officer (IO) is only required to have "reason to believe" based on some material in his possession, a standard higher than under BNS/BNSS but lower than a prima facie case. HC declined to examine in writ jurisdiction whether the transactions fit the definition of "benami transaction" under s.2(9), as this falls within the domain of the Adjudicating Authority. HC held that prior written approval of the Approving Authority under s.24(3) need not be supplied with the attachment order, though it must be provided on request. Liberty was reserved to A to seek relief before the Adjudicating Authority. The writ petition was dismissed.
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