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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Block assessment - The notice u/s 158BC was issued by AO on 5th May, 2000, which was served on 08th May, 2000. The time limit for passing assessment for Block Period was two years from the end of month in which notice u/s 158BC was served, i.e. 31st May, 2002. The Block Period assessment order passed by AO u/s 158BC(c) read with Section 158BD, was dated 30th May, 2002, which is within limitation period. Thus, the contentions of the assessee are devoid of any merit and are hereby rejected. - AT
Block assessment - The notice u/s 158BC was issued by AO on 5th May, 2000, which was served on 08th May, 2000. The time limit for passing assessment for Block Period was two years from the end of month in which notice u/s 158BC was served, i.e. 31st May, 2002. The Block Period assessment order passed by AO u/s 158BC(c) read with Section 158BD, was dated 30th May, 2002, which is within limitation period. Thus, the contentions of the assessee are devoid of any merit and are hereby rejected. - AT
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