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 - Notice issued u/s 148(A)(b) - Period of limitation - It is pertinent to mention here that since the defect committed by the Revenue by giving less than seven days' time to the Assessee to reply to the Notice issued u/s 148(A)(b) of the Act, is a curable defect; as such, the Revenue, if the law so permits, can issue fresh letter to the Assessee in continuation to the Notice issued u/s 148(A)(b) of the Act by giving him at least seven days' time and not more than thirty days to file its show-cause reply and proceed in the matter. - HC
Reopening of assessment u/s 147 - Notice issued u/s 148(A)(b) - Period of limitation - It is pertinent to mention here that since the defect committed by the Revenue by giving less than seven days' time to the Assessee to reply to the Notice issued u/s 148(A)(b) of the Act, is a curable defect; as such, the Revenue, if the law so permits, can issue fresh letter to the Assessee in continuation to the Notice issued u/s 148(A)(b) of the Act by giving him at least seven days' time and not more than thirty days to file its show-cause reply and proceed in the matter. - HC
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