Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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ITAT allowed the assessee's appeal and quashed the assessment order u/s 143(3) r/w 144B and the rectification order u/s 154. It held that the AO, having invoked s.50C(2), was bound to await the DVO's report and follow the procedure incorporating s.16A of the Wealth-tax Act, including affording the assessee an opportunity of being heard. Proceeding on stamp duty valuation without the DVO's determination violated the mandatory procedural safeguard and principles of natural justice, rendering the assessment unsustainable. ITAT further held that the CIT(A) failed to deal with cited precedents and denied effective opportunity regarding cost and expense claims, vitiating the appellate order.
ITAT allowed the assessee's appeal and quashed the assessment order u/s 143(3) r/w 144B and the rectification order u/s 154. It held that the AO, having invoked s.50C(2), was bound to await the DVO's report and follow the procedure incorporating s.16A of the Wealth-tax Act, including affording the assessee an opportunity of being heard. Proceeding on stamp duty valuation without the DVO's determination violated the mandatory procedural safeguard and principles of natural justice, rendering the assessment unsustainable. ITAT further held that the CIT(A) failed to deal with cited precedents and denied effective opportunity regarding cost and expense claims, vitiating the appellate order.
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