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 - Though in the instant case, the petitioner has written a letter in response to the reasons received by it, yet it has not filed any objections. In fact, in the said letter, a Power of Attorney, copy of ITR, Bank statement have only been enclosed and no specific objection has been raised. Consequently, this Court is in agreement with the preliminary objection raised by the learned counsel for the respondent revenue that the present writ petition is premature. - HC
Reopening of assessment u/s 147 - Though in the instant case, the petitioner has written a letter in response to the reasons received by it, yet it has not filed any objections. In fact, in the said letter, a Power of Attorney, copy of ITR, Bank statement have only been enclosed and no specific objection has been raised. Consequently, this Court is in agreement with the preliminary objection raised by the learned counsel for the respondent revenue that the present writ petition is premature. - HC
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