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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Rectification that withdrew a claimed deduction for an export-oriented unit without stating reasons or issuing any show-cause notice was treated as an impermissible change of opinion rather than correction of a mistake apparent on the record; absence of material justifying rectification and lack of opportunity to be heard rendered the CPC's action unsustainable. The operative effect directed restoration of the deduction as reflected in the assessment intimation, and the assessing officer was ordered to allow the deduction previously granted in the intimation.
Rectification that withdrew a claimed deduction for an export-oriented unit without stating reasons or issuing any show-cause notice was treated as an impermissible change of opinion rather than correction of a mistake apparent on the record; absence of material justifying rectification and lack of opportunity to be heard rendered the CPC's action unsustainable. The operative effect directed restoration of the deduction as reflected in the assessment intimation, and the assessing officer was ordered to allow the deduction previously granted in the intimation.
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