Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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Binding coordinate Bench orders in the assessee's own case had already directed grant of approval for exemption under section 10(23C)(vi) from assessment year 2018-19 onwards, and that earlier determination could not be displaced by a later administrative error. The Commissioner (Exemptions) had incorrectly recorded that sections 11 and 12 applied, but the Tribunal held that this mistake did not override the prior directions. The Revenue's argument that the application date confined relief to assessment year 2019-20 was rejected because judicial discipline required following the earlier view on entitlement for assessment year 2018-19. The Assessing Officer was directed to give effect to exemption under section 10(23C)(vi).
Binding coordinate Bench orders in the assessee's own case had already directed grant of approval for exemption under section 10(23C)(vi) from assessment year 2018-19 onwards, and that earlier determination could not be displaced by a later administrative error. The Commissioner (Exemptions) had incorrectly recorded that sections 11 and 12 applied, but the Tribunal held that this mistake did not override the prior directions. The Revenue's argument that the application date confined relief to assessment year 2019-20 was rejected because judicial discipline required following the earlier view on entitlement for assessment year 2018-19. The Assessing Officer was directed to give effect to exemption under section 10(23C)(vi).
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