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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Fresh assessment after Tribunal remand must be completed within the statutory period under Section 153, and failure to do so bars any further demand. The High Court held that where no assessment order was passed within the extended limitation period, the Assessing Officer could not keep the matter pending or rely on earlier findings independently of a consequential order. The consequence of non-compliance was that the return of income had to be accepted as filed. The writ petition was therefore allowed, and the assessee's return for AY 2014-15 was directed to be accepted.
Fresh assessment after Tribunal remand must be completed within the statutory period under Section 153, and failure to do so bars any further demand. The High Court held that where no assessment order was passed within the extended limitation period, the Assessing Officer could not keep the matter pending or rely on earlier findings independently of a consequential order. The consequence of non-compliance was that the return of income had to be accepted as filed. The writ petition was therefore allowed, and the assessee's return for AY 2014-15 was directed to be accepted.
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