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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Validity of reopening of assessment u/s 147 - appropriate authority - if Joint Commissioner approves the proceedings/ proposal sent by the Assessing Officer to be a fit case, then, in the opinion of this Court, the approval under Section 151 giving details of approving authority as Principal Commissioner of Income Tax in itself will not make the approval invalid - In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more so when it bears DIN & Document Number. - HC
Validity of reopening of assessment u/s 147 - appropriate authority - if Joint Commissioner approves the proceedings/ proposal sent by the Assessing Officer to be a fit case, then, in the opinion of this Court, the approval under Section 151 giving details of approving authority as Principal Commissioner of Income Tax in itself will not make the approval invalid - In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more so when it bears DIN & Document Number. - HC
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