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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Filing of Form 1 under IDS 2016, coupled with non-payment of tax/surcharge/penalty, was held to constitute fresh tangible material for A.Y. 2017-18 under s.197(b) of the Finance Act, 2016, so reopening could not be assailed for lack of material. However, reassessment was quashed because the notice u/s 148 was issued by the jurisdictional AO instead of the faceless AO, rendering the notice void. Separately, for a notice issued beyond three years, sanction ought to have been obtained from the specified authority u/s 151(ii); approval from PCIT was held incompetent, vitiating jurisdiction. On merits, in absence of proved service of Form 2, s.197(b) could not be invoked and the s.69A addition was deleted; consequential s.271AAC penalty failed. - ITAT
Filing of Form 1 under IDS 2016, coupled with non-payment of tax/surcharge/penalty, was held to constitute fresh tangible material for A.Y. 2017-18 under s.197(b) of the Finance Act, 2016, so reopening could not be assailed for lack of material. However, reassessment was quashed because the notice u/s 148 was issued by the jurisdictional AO instead of the faceless AO, rendering the notice void. Separately, for a notice issued beyond three years, sanction ought to have been obtained from the specified authority u/s 151(ii); approval from PCIT was held incompetent, vitiating jurisdiction. On merits, in absence of proved service of Form 2, s.197(b) could not be invoked and the s.69A addition was deleted; consequential s.271AAC penalty failed. - ITAT
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