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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Assessment u/s 153C/153A - Computation of the Relevant Assessment Years Block - Jurisdiction for Reopening Assessments - The Delhi High Court meticulously analyzed the legal and procedural framework governing the reassessment process following search operations. It provided clarity on the computation of the relevant block of years for assessment, the jurisdictional reach of the Income Tax authorities in light of the 2017 amendments, and the procedural safeguards intended to ensure fairness in the reassessment process. The judgments underscore the necessity for a precise satisfaction note and uphold the legislative amendments aimed at capturing undisclosed income extending beyond the standard six-year limitation period, subject to meeting specific criteria outlined in the statute.
Assessment u/s 153C/153A - Computation of the Relevant Assessment Years Block - Jurisdiction for Reopening Assessments - The Delhi High Court meticulously analyzed the legal and procedural framework governing the reassessment process following search operations. It provided clarity on the computation of the relevant block of years for assessment, the jurisdictional reach of the Income Tax authorities in light of the 2017 amendments, and the procedural safeguards intended to ensure fairness in the reassessment process. The judgments underscore the necessity for a precise satisfaction note and uphold the legislative amendments aimed at capturing undisclosed income extending beyond the standard six-year limitation period, subject to meeting specific criteria outlined in the statute.
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