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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The High Court addressed the issue of faceless assessment of income escaping assessment u/s 151A scheme. It held that notices must be issued in a faceless manner as mandated, without physical interface. The scheme allows for automated allocation and issuance of notices u/s 148 in a faceless manner. The statute aims to prevent prejudice and bias by automated allocation through risk management strategy. The Court cited judgments supporting automated issuance of notices without any interface. The Court clarified that there is no fundamental right for an assessee to demand manual issuance of notices. The Department must adhere to the scheme for assessment, re-assessment, and issuance of notices. If the Department withdraws notices, fresh notices may be issued following the scheme and u/s 151A, allowing the petitioner to respond under Section 148.
The High Court addressed the issue of faceless assessment of income escaping assessment u/s 151A scheme. It held that notices must be issued in a faceless manner as mandated, without physical interface. The scheme allows for automated allocation and issuance of notices u/s 148 in a faceless manner. The statute aims to prevent prejudice and bias by automated allocation through risk management strategy. The Court cited judgments supporting automated issuance of notices without any interface. The Court clarified that there is no fundamental right for an assessee to demand manual issuance of notices. The Department must adhere to the scheme for assessment, re-assessment, and issuance of notices. If the Department withdraws notices, fresh notices may be issued following the scheme and u/s 151A, allowing the petitioner to respond under Section 148.
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