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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Validity of reopening of assessment - grievance raised that the objections raised were not specifically dealt - Procedure prescribed u/s 148A followed or not? - The Central Board of Direct Taxes (CBDT) after the decision of Supreme Court in Ashish Agarwal issued guidelines for issuance of notice u/s 148 - The High court found that the impugned order did not adhere to the prescribed procedures u/s 148A of the Act and the CBDT guidelines. The order was quashed, and the matter was remitted back to the respondent for further proceedings in accordance with the law. - Consequently, the HC remanded the matter back to proceed with notice u/s 148-A(b) in accordance with law.
Validity of reopening of assessment - grievance raised that the objections raised were not specifically dealt - Procedure prescribed u/s 148A followed or not? - The Central Board of Direct Taxes (CBDT) after the decision of Supreme Court in Ashish Agarwal issued guidelines for issuance of notice u/s 148 - The High court found that the impugned order did not adhere to the prescribed procedures u/s 148A of the Act and the CBDT guidelines. The order was quashed, and the matter was remitted back to the respondent for further proceedings in accordance with the law. - Consequently, the HC remanded the matter back to proceed with notice u/s 148-A(b) in accordance with law.
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