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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Ex parte adjudication was assailed on the ground that the show cause notice and order were uploaded only under an "Additional Notices" tab and were not effectively served, resulting in denial of a reasonable opportunity of hearing and breach of natural justice. Applying the approach adopted in a comparable case, the adjudication was held to warrant interference because no reply had been filed due to lack of proper notice; consequently, the impugned order was set aside and the matter remanded to the adjudicating authority for fresh consideration, subject to conditions due to the petitioner's belated approach, while the challenge to the impugned notifications remained pending. - HC
Ex parte adjudication was assailed on the ground that the show cause notice and order were uploaded only under an "Additional Notices" tab and were not effectively served, resulting in denial of a reasonable opportunity of hearing and breach of natural justice. Applying the approach adopted in a comparable case, the adjudication was held to warrant interference because no reply had been filed due to lack of proper notice; consequently, the impugned order was set aside and the matter remanded to the adjudicating authority for fresh consideration, subject to conditions due to the petitioner's belated approach, while the challenge to the impugned notifications remained pending. - HC
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