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 Appellate Tribunal considered the validity of a re-assessment notice issued by the jurisdictional AO instead of the designated Faceless Assessing Officer (FAO) as required by Notification No 18/2022. The Tribunal held that the Scheme formulated by the CBDT applies to both assessment and issuance of notice u/s 148 of the Act. It clarified that only the FAO, not the JAO, can issue notices u/s 148. The Tribunal emphasized that Section 144B applies to assessment or reassessment, not to the issuance of notices. Citing a case, the Tribunal deemed notices issued by JAOs invalid u/s 151A of the Act. Consequently, the Tribunal declared the assessment based on JAO's notice as void ab initio, ruling in favor of the assessee.
The Appellate Tribunal considered the validity of a re-assessment notice issued by the jurisdictional AO instead of the designated Faceless Assessing Officer (FAO) as required by Notification No 18/2022. The Tribunal held that the Scheme formulated by the CBDT applies to both assessment and issuance of notice u/s 148 of the Act. It clarified that only the FAO, not the JAO, can issue notices u/s 148. The Tribunal emphasized that Section 144B applies to assessment or reassessment, not to the issuance of notices. Citing a case, the Tribunal deemed notices issued by JAOs invalid u/s 151A of the Act. Consequently, the Tribunal declared the assessment based on JAO's notice as void ab initio, ruling in favor of the assessee.
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