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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Reopening of assessment u/s 147 - The High Court noted that the extended period of six years for reassessment could only be invoked under specific circumstances, one of which is the failure to disclose all material facts. - The Court observed that while the Assessing Officer had invoked the extended period of limitation for reassessment, there was no finding in the reasons furnished for reassessment that the petitioner had failed to disclose fully and truly all material facts necessary for assessment. Without such a finding, the Court held that the entire proceeding would be void and a nullity.
Reopening of assessment u/s 147 - The High Court noted that the extended period of six years for reassessment could only be invoked under specific circumstances, one of which is the failure to disclose all material facts. - The Court observed that while the Assessing Officer had invoked the extended period of limitation for reassessment, there was no finding in the reasons furnished for reassessment that the petitioner had failed to disclose fully and truly all material facts necessary for assessment. Without such a finding, the Court held that the entire proceeding would be void and a nullity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
