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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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Signed approval by the prescribed authority is a jurisdictional precondition to issuing a reassessment notice and safeguards against arbitrary reopening. The approving authority must record satisfaction, after considering the recorded reasons and supporting material, through a manual or digital signature. A DIN, electronic transmission, or printed officer name and designation may establish authenticity but cannot replace the required signature. A curative provision introduced after the relevant approval cannot validate the defect. An unsigned approval therefore cannot confer reassessment jurisdiction, rendering consequential reassessment action unsustainable.
Signed approval by the prescribed authority is a jurisdictional precondition to issuing a reassessment notice and safeguards against arbitrary reopening. The approving authority must record satisfaction, after considering the recorded reasons and supporting material, through a manual or digital signature. A DIN, electronic transmission, or printed officer name and designation may establish authenticity but cannot replace the required signature. A curative provision introduced after the relevant approval cannot validate the defect. An unsigned approval therefore cannot confer reassessment jurisdiction, rendering consequential reassessment action unsustainable.
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