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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Reopening of assessment - notice u/s 148 barred by limitation - Though the notice u/s 148(2) was first published in the newspaper on 09.12.2017 which was beyond the period of limitation but the record reveals that the notice was first issued on 30.03.2017, which as per Section 149(1)(b) was within limitation - the contention that the notice was barred by time is negatived - reassessment valid
Reopening of assessment - notice u/s 148 barred by limitation - Though the notice u/s 148(2) was first published in the newspaper on 09.12.2017 which was beyond the period of limitation but the record reveals that the notice was first issued on 30.03.2017, which as per Section 149(1)(b) was within limitation - the contention that the notice was barred by time is negatived - reassessment valid
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