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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Petition challenges validity of an assessment completed under faceless assessment where the taxpayer was prevented by the portal from filing a reply and from obtaining a personal hearing; an online grievance remained unredressed. The court found these procedural deprivations breached the principles of natural justice, declined to consider the substantive merits, and held the assessment and consequential demand invalid for want of opportunity to be heard. The operative effect directs reopening of assessment proceedings, permitting filing of the reply and affording an opportunity of hearing before any fresh orders are passed.
Petition challenges validity of an assessment completed under faceless assessment where the taxpayer was prevented by the portal from filing a reply and from obtaining a personal hearing; an online grievance remained unredressed. The court found these procedural deprivations breached the principles of natural justice, declined to consider the substantive merits, and held the assessment and consequential demand invalid for want of opportunity to be heard. The operative effect directs reopening of assessment proceedings, permitting filing of the reply and affording an opportunity of hearing before any fresh orders are passed.
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