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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Intimation under section 143(1)(a) incorporating an ICDS adjustment was quashed by the jurisdictional High Court; consequently the ICDS adjustment cannot stand in the assessment computation and must be removed from the assessment under section 143(3). The tribunal directs the assessing officer to modify the total income in the assessment order to exclude the ICDS adjustment reflected in the quashed intimation, giving full consequential effect to the High Court quashing when finalising the assessment computation.
Intimation under section 143(1)(a) incorporating an ICDS adjustment was quashed by the jurisdictional High Court; consequently the ICDS adjustment cannot stand in the assessment computation and must be removed from the assessment under section 143(3). The tribunal directs the assessing officer to modify the total income in the assessment order to exclude the ICDS adjustment reflected in the quashed intimation, giving full consequential effect to the High Court quashing when finalising the assessment computation.
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