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 assessment u/s 144-B r/w Section 143(2) - Faceless assessment - Portal window was closed, for filing of reply - It is an open and shut case before us that the Petitioner indeed sought an adjournment till 16.12.2022 vide his email dated 08.12.2022, which is not denied by the Department. Clause (xiii) of Section 144B(1) indicates that the Assessee can file a reply on the date and time as specified or also within the extended time on the basis of his request application. There is no dispute that the Department shut down the window on 09.12.2022 and neither accepted the request of the Petitioner, nor rejected it. - Matter restored back - HC
Validity of assessment u/s 144-B r/w Section 143(2) - Faceless assessment - Portal window was closed, for filing of reply - It is an open and shut case before us that the Petitioner indeed sought an adjournment till 16.12.2022 vide his email dated 08.12.2022, which is not denied by the Department. Clause (xiii) of Section 144B(1) indicates that the Assessee can file a reply on the date and time as specified or also within the extended time on the basis of his request application. There is no dispute that the Department shut down the window on 09.12.2022 and neither accepted the request of the Petitioner, nor rejected it. - Matter restored back - HC
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