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 - Period of limitation to issue notice - typographical error in the notice issued wherein the assessment year has been mentioned as 2015-16 instead of 2010-11 - By the said corrigendum, it cannot be said that it has sought to cure a procedural irregularity as contemplated under Section 292- B of the Income Tax Act, 1961 and it has to be held that they have invoked the jurisdiction to reopen the assessment for the year 2010-2011 only after issuance of the said corrigendum on 11.04.2017 which is clearly time barred. - HC
Reopening of assessment u/s 147 - Period of limitation to issue notice - typographical error in the notice issued wherein the assessment year has been mentioned as 2015-16 instead of 2010-11 - By the said corrigendum, it cannot be said that it has sought to cure a procedural irregularity as contemplated under Section 292- B of the Income Tax Act, 1961 and it has to be held that they have invoked the jurisdiction to reopen the assessment for the year 2010-2011 only after issuance of the said corrigendum on 11.04.2017 which is clearly time barred. - HC
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