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 ex-parte assessment order u/s. 144 r.w.s. 147 - Delay in filing the appeal before the CIT(A) - The ITAT Mumbai allowed the appeal filed by the assessee, condoning the delay in filing the appeal due to the bona fide reasons provided. The Tribunal invalidated the reassessment proceedings and the assessment order due to the failure of the Revenue to produce evidence of the issuance and service of the notice u/s 148. Consequently, the grounds related to the validity of the reassessment proceedings and the assessment order were allowed, and the merits of the additions to the total income were left open.
Validity of ex-parte assessment order u/s. 144 r.w.s. 147 - Delay in filing the appeal before the CIT(A) - The ITAT Mumbai allowed the appeal filed by the assessee, condoning the delay in filing the appeal due to the bona fide reasons provided. The Tribunal invalidated the reassessment proceedings and the assessment order due to the failure of the Revenue to produce evidence of the issuance and service of the notice u/s 148. Consequently, the grounds related to the validity of the reassessment proceedings and the assessment order were allowed, and the merits of the additions to the total income were left open.
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