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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Validity of assessments framed under s.153A turned on whether mandatory approval under s.153D was granted with due application of mind. Where a single, joint approval was accorded for seven assessment years and the record did not evidence any meaningful interaction or scrutiny by the approving authority of the draft orders, the approval was held to be mechanical, perfunctory, and merely ritualistic, failing the statutory safeguard under s.153D. Consequently, the assessments founded on such symbolic approval were vitiated and were quashed, and the appeal was allowed. - ITAT
Validity of assessments framed under s.153A turned on whether mandatory approval under s.153D was granted with due application of mind. Where a single, joint approval was accorded for seven assessment years and the record did not evidence any meaningful interaction or scrutiny by the approving authority of the draft orders, the approval was held to be mechanical, perfunctory, and merely ritualistic, failing the statutory safeguard under s.153D. Consequently, the assessments founded on such symbolic approval were vitiated and were quashed, and the appeal was allowed. - ITAT
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