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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Limitation for passing a assessment order - Consequential order passed by the assessing authority beyond the time limit specified u/s 153 (2A) - The High Court examined the statutory provisions and concluded that the time limit applies to consequential orders following a remand by an appellate or revisional authority. The purpose of this provision is to ensure expeditious assessments and timely receipt of government dues. In the case at hand, despite specific directions from the Tribunal, the Assessing Authority failed to pass the consequential order within the prescribed time limit, leading to prejudice for the assessee.
Limitation for passing a assessment order - Consequential order passed by the assessing authority beyond the time limit specified u/s 153 (2A) - The High Court examined the statutory provisions and concluded that the time limit applies to consequential orders following a remand by an appellate or revisional authority. The purpose of this provision is to ensure expeditious assessments and timely receipt of government dues. In the case at hand, despite specific directions from the Tribunal, the Assessing Authority failed to pass the consequential order within the prescribed time limit, leading to prejudice for the assessee.
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