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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Demand of additional tax on simple processing of income - Applicability of provision of Section 143(1A) where assessment may have been completed u/s 143(3) - The High Court clarified that Section 143(1A) applies only to cases arising from processing under Section 143(1)(a) and does not extend to scrutiny assessments conducted u/s 143(3). It emphasized that once scrutiny assessment proceedings are initiated, the imposition of additional tax u/s 143(1A) is not contemplated by the legislature. - The Court underscored the fundamental principle that there can only be one assessment order for one assessment year, and once scrutiny assessment is completed, any earlier intimation loses its effect.
Demand of additional tax on simple processing of income - Applicability of provision of Section 143(1A) where assessment may have been completed u/s 143(3) - The High Court clarified that Section 143(1A) applies only to cases arising from processing under Section 143(1)(a) and does not extend to scrutiny assessments conducted u/s 143(3). It emphasized that once scrutiny assessment proceedings are initiated, the imposition of additional tax u/s 143(1A) is not contemplated by the legislature. - The Court underscored the fundamental principle that there can only be one assessment order for one assessment year, and once scrutiny assessment is completed, any earlier intimation loses its effect.
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