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 u/s 147 - Reasons were supplied to the assessee only on 21.11.2017 and assessee on the same day filed the objections to the reopening of the assessment which have been disposed of vide Order Dated 05.12.2017 - A.O. within 23 days after disposing of the objections of the assessee passed the impugned re-assessment order Dated 28.12.2017. Thus, no time of four weeks have been granted to the assessee to take remedial action - Thus re-assessment order framed u/s 147/143(3) is bad in Law and deserves to be quashed. - AT
Reopening of assessment u/s 147 - Reasons were supplied to the assessee only on 21.11.2017 and assessee on the same day filed the objections to the reopening of the assessment which have been disposed of vide Order Dated 05.12.2017 - A.O. within 23 days after disposing of the objections of the assessee passed the impugned re-assessment order Dated 28.12.2017. Thus, no time of four weeks have been granted to the assessee to take remedial action - Thus re-assessment order framed u/s 147/143(3) is bad in Law and deserves to be quashed. - AT
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