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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Validity of reassessment proceedings challenged - capital gain on co-owned land sale - reassessment based on DVO report alleging suppression of lower valuation - reasons recorded did not mention forming reason to believe due to DVO report in co-owner's case - reliance on DVO report to justify reopening untenable as no fresh material part of recorded reasons - petitioner fully disclosed material facts during original assessment - change of opinion for reopening by impugned notice u/s 148 untenable - impugned notice unsustainable - assessee entitled to benefit enjoyed by co-owners whose valuation accepted - permitting impugned notice an exercise in futility - assessee appeal allowed.
Validity of reassessment proceedings challenged - capital gain on co-owned land sale - reassessment based on DVO report alleging suppression of lower valuation - reasons recorded did not mention forming reason to believe due to DVO report in co-owner's case - reliance on DVO report to justify reopening untenable as no fresh material part of recorded reasons - petitioner fully disclosed material facts during original assessment - change of opinion for reopening by impugned notice u/s 148 untenable - impugned notice unsustainable - assessee entitled to benefit enjoyed by co-owners whose valuation accepted - permitting impugned notice an exercise in futility - assessee appeal allowed.
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