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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Office memorandum clarifies the procedure when a taxpayer's MAP application under Rule 44G is successfully resolved while an income tax appeal is pending before the Commissioner of Income Tax (Appeals). Following mutual agreement, the taxpayer must accept or reject the resolution and provide proof of appeal withdrawal. Since no explicit process existed for withdrawal at the CIT(A) stage, the memorandum directs CIT(A) offices to issue an intimation confirming acceptance of withdrawal of the appeal or specific grounds covered by the MAP resolution. This intimation will constitute valid proof of withdrawal for purposes of Rule 44G(8).
Office memorandum clarifies the procedure when a taxpayer's MAP application under Rule 44G is successfully resolved while an income tax appeal is pending before the Commissioner of Income Tax (Appeals). Following mutual agreement, the taxpayer must accept or reject the resolution and provide proof of appeal withdrawal. Since no explicit process existed for withdrawal at the CIT(A) stage, the memorandum directs CIT(A) offices to issue an intimation confirming acceptance of withdrawal of the appeal or specific grounds covered by the MAP resolution. This intimation will constitute valid proof of withdrawal for purposes of Rule 44G(8).
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