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 quashed the impugned order rejecting the application for release of jewellery requisitioned u/s 132A, holding that it was passed by an officer who did not hold jurisdiction over the petitioner, contrary to directions earlier issued by the MP HC. The Court declined to examine the merits of the petitioner's claim of ownership or the evidentiary sufficiency regarding the seized jewellery. Observing that the case had since been centralized, HC directed the Deputy Commissioner of Income Tax, Central Circle 5(3), Mumbai, now the jurisdictional officer, to decide the petitioner's application afresh on its own merits, after granting due opportunity of hearing and calling for further documents if required.
HC quashed the impugned order rejecting the application for release of jewellery requisitioned u/s 132A, holding that it was passed by an officer who did not hold jurisdiction over the petitioner, contrary to directions earlier issued by the MP HC. The Court declined to examine the merits of the petitioner's claim of ownership or the evidentiary sufficiency regarding the seized jewellery. Observing that the case had since been centralized, HC directed the Deputy Commissioner of Income Tax, Central Circle 5(3), Mumbai, now the jurisdictional officer, to decide the petitioner's application afresh on its own merits, after granting due opportunity of hearing and calling for further documents if required.
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