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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The central issue was whether the approval authorizing a special audit under s.142(2A) complied with Circular No.19/2019 by bearing a DIN and requisite manual-issuance justification; the court held the approval dated 06.02.2025 lacked a DIN and any exceptional-circumstances endorsement, violating the Circular and settled precedent that jurisdictional communications (including approvals/sanctions) must carry a DIN. Legal basis: Circular No.19/2019 and prior HC rulings invalidating DIN-less sanctions. Outcome: the approval is non est in law and the subsequent order directing a special audit is without jurisdiction - decided for the assessee. - HC
The central issue was whether the approval authorizing a special audit under s.142(2A) complied with Circular No.19/2019 by bearing a DIN and requisite manual-issuance justification; the court held the approval dated 06.02.2025 lacked a DIN and any exceptional-circumstances endorsement, violating the Circular and settled precedent that jurisdictional communications (including approvals/sanctions) must carry a DIN. Legal basis: Circular No.19/2019 and prior HC rulings invalidating DIN-less sanctions. Outcome: the approval is non est in law and the subsequent order directing a special audit is without jurisdiction - decided for the assessee. - HC
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