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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Block assessment scope under Chapter XIV-B is governed by the definition of "block period"; where an Assessment Year falls within that period Section 158BA(2) causes pending proceedings to abate insofar as they relate to the block period. The court held that (re)assessment for AY 2022 23 falls within the block period conceptually, but denied writ relief because factual prerequisites were not established-no material showed the search disclosed the petitioner's total undisclosed income or linked company searches to his individual income-so the AO retains jurisdiction under Chapter XIV B if statutory conditions are met.
Block assessment scope under Chapter XIV-B is governed by the definition of "block period"; where an Assessment Year falls within that period Section 158BA(2) causes pending proceedings to abate insofar as they relate to the block period. The court held that (re)assessment for AY 2022 23 falls within the block period conceptually, but denied writ relief because factual prerequisites were not established-no material showed the search disclosed the petitioner's total undisclosed income or linked company searches to his individual income-so the AO retains jurisdiction under Chapter XIV B if statutory conditions are met.
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