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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Registration under section 12A was originally granted and renewed by the prescribed authority empowered to grant or withdraw such registration. The tribunal held that section 127 permits transfer of cases among assessing officers but does not permit transfer of power to Commissioners who are not assessing officers; therefore a different PCIT lacked jurisdiction to cancel the registration granted by the empowered authority. Consequence: the cancellation order issued without jurisdiction was quashed and the assessee's registration restored, and the appeal was allowed.
Registration under section 12A was originally granted and renewed by the prescribed authority empowered to grant or withdraw such registration. The tribunal held that section 127 permits transfer of cases among assessing officers but does not permit transfer of power to Commissioners who are not assessing officers; therefore a different PCIT lacked jurisdiction to cancel the registration granted by the empowered authority. Consequence: the cancellation order issued without jurisdiction was quashed and the assessee's registration restored, and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.