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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Whether assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
Whether assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
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