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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The HC held that an order passed before the hearing date fixed in the show cause notice, and before receipt of the petitioner's representation, violated principles of natural justice because no effective opportunity of hearing was afforded. The impugned order was quashed on that limited ground, the matter was remanded for fresh consideration after giving the petitioner an opportunity to reply and be heard, and any recovery based on the quashed order was held not to survive.
The HC held that an order passed before the hearing date fixed in the show cause notice, and before receipt of the petitioner's representation, violated principles of natural justice because no effective opportunity of hearing was afforded. The impugned order was quashed on that limited ground, the matter was remanded for fresh consideration after giving the petitioner an opportunity to reply and be heard, and any recovery based on the quashed order was held not to survive.
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