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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Reassessment notice u/s 148 was validly issued within the six-year time limit. The Assessing Officer (AO) recorded reasons for reopening on 19.03.2018, prior to obtaining sanction u/s 151 on 23.03.2018, and issued the notice on 27.03.2018, before the deadline of 31.03.2018. The AO followed the procedure mandated by the Income-tax Act, 1961, and the Supreme Court's decision in GKN Driveshafts (India) Ltd. case. The AO had valid reasons to believe based on information from the investigation wing about bogus entries provided by entry operators. Regarding estimation of income from bogus purchases, following the Pankaj K. Chaudhary case, the disallowance was restricted to 6% of the disputed bogus purchases, as the books of account were not rejected.
Reassessment notice u/s 148 was validly issued within the six-year time limit. The Assessing Officer (AO) recorded reasons for reopening on 19.03.2018, prior to obtaining sanction u/s 151 on 23.03.2018, and issued the notice on 27.03.2018, before the deadline of 31.03.2018. The AO followed the procedure mandated by the Income-tax Act, 1961, and the Supreme Court's decision in GKN Driveshafts (India) Ltd. case. The AO had valid reasons to believe based on information from the investigation wing about bogus entries provided by entry operators. Regarding estimation of income from bogus purchases, following the Pankaj K. Chaudhary case, the disallowance was restricted to 6% of the disputed bogus purchases, as the books of account were not rejected.
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