Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.
Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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