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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ITAT dismissed the assessee's appeal as time-barred, refusing to condone an inordinate delay of 562 days in filing. The assessee's explanation that the delay was due to a period of custody was rejected, as custody ended long before the impugned CIT(A) order and the filing of appeal, and multiple hearing notices were duly issued to the assessee and its authorised representative. ITAT held that no sufficient cause was shown for condonation under settled law. Though the Tribunal noted that the penalty notices under s. 271(1)(c) were defective for not specifying a clear charge, the appeal itself was not entertained on account of the unexplained delay.
ITAT dismissed the assessee's appeal as time-barred, refusing to condone an inordinate delay of 562 days in filing. The assessee's explanation that the delay was due to a period of custody was rejected, as custody ended long before the impugned CIT(A) order and the filing of appeal, and multiple hearing notices were duly issued to the assessee and its authorised representative. ITAT held that no sufficient cause was shown for condonation under settled law. Though the Tribunal noted that the penalty notices under s. 271(1)(c) were defective for not specifying a clear charge, the appeal itself was not entertained on account of the unexplained delay.
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