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 a final assessment under section 144C(13) hinges on the applicable limitation period, and the article explains that limitation must be determined by reading section 144C with section 153 together because both provisions overlap and are interdependent. Following precedent from a High Court and an ITAT decision, the note records that a final assessment for the specified year was treated as timebarred when limitation under section 153 read with section 144C was applied, resulting in quashing of the order, while parties retain liberty to revive the appeal pending the Supreme Court largerbench decision on the issue.
Validity of a final assessment under section 144C(13) hinges on the applicable limitation period, and the article explains that limitation must be determined by reading section 144C with section 153 together because both provisions overlap and are interdependent. Following precedent from a High Court and an ITAT decision, the note records that a final assessment for the specified year was treated as timebarred when limitation under section 153 read with section 144C was applied, resulting in quashing of the order, while parties retain liberty to revive the appeal pending the Supreme Court largerbench decision on the issue.
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