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 ITAT held that the period of limitation for issuing a notice u/s 153C is six years from the end of the financial year preceding the date of recording satisfaction. In this case, the satisfaction was recorded on 31.10.2018 for AY 2018-19, so AYs 2011-12 and 2012-13 were outside the 6-year limit. The notice for these years was deemed not maintainable and quashed. The satisfaction note by the AO lacked a direct correlation between the seized material and the relevant assessment years as required by section 153C. As the seized documents did not establish this link, the reasoning for reopening the assessment was deemed vague and invalid. Following the precedent set in CIT vs. Sinhgad Technical Education Society, the reassessment proceedings u/s 153C were quashed, and the assessee's appeals were allowed.
The ITAT held that the period of limitation for issuing a notice u/s 153C is six years from the end of the financial year preceding the date of recording satisfaction. In this case, the satisfaction was recorded on 31.10.2018 for AY 2018-19, so AYs 2011-12 and 2012-13 were outside the 6-year limit. The notice for these years was deemed not maintainable and quashed. The satisfaction note by the AO lacked a direct correlation between the seized material and the relevant assessment years as required by section 153C. As the seized documents did not establish this link, the reasoning for reopening the assessment was deemed vague and invalid. Following the precedent set in CIT vs. Sinhgad Technical Education Society, the reassessment proceedings u/s 153C were quashed, and the assessee's appeals were allowed.
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