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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Notices issued to the email address recorded in the tax database were held valid in law; non-service cannot be attributed to the Assessing Officer where the assessee provided or allowed an inaccessible email ID, and the assessee bears the duty to furnish and monitor a valid communication address, but must still be afforded an opportunity to be heard. Where pandemic-related non-communication plausibly explains delayed compliance, delay in filing appeals to the CIT(A) was condoned and the appeals were restored for adjudication on merits, subject to a protective condition that the assessee deposit twenty percent of the demand; no fresh assessment or remand to the Assessing Officer was ordered.
Notices issued to the email address recorded in the tax database were held valid in law; non-service cannot be attributed to the Assessing Officer where the assessee provided or allowed an inaccessible email ID, and the assessee bears the duty to furnish and monitor a valid communication address, but must still be afforded an opportunity to be heard. Where pandemic-related non-communication plausibly explains delayed compliance, delay in filing appeals to the CIT(A) was condoned and the appeals were restored for adjudication on merits, subject to a protective condition that the assessee deposit twenty percent of the demand; no fresh assessment or remand to the Assessing Officer was ordered.
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