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 the rectification order u/s 154 invalid and non est as it did not bear a DIN in the manner mandated by CBDT Circular 19/2019 and thus was deemed never to have been issued. On facts, HC inferred that the order was backdated to 29.03.2024 to avoid limitation, since a notice proposing rectification u/s 154(3) was issued only on 20.06.2024, after expiry of the four-year period u/s 154(7) on 31.03.2024. HC further held that a separate notice granting opportunity of hearing under s.154(3) was mandatory as the rectification increased total income. The impugned rectification order was quashed and set aside.
HC held the rectification order u/s 154 invalid and non est as it did not bear a DIN in the manner mandated by CBDT Circular 19/2019 and thus was deemed never to have been issued. On facts, HC inferred that the order was backdated to 29.03.2024 to avoid limitation, since a notice proposing rectification u/s 154(3) was issued only on 20.06.2024, after expiry of the four-year period u/s 154(7) on 31.03.2024. HC further held that a separate notice granting opportunity of hearing under s.154(3) was mandatory as the rectification increased total income. The impugned rectification order was quashed and set aside.
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