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 notice u/s 143(2) of the Income Tax Act was issued on 15.10.2013, beyond the prescribed time limit of six months from the end of the assessment year, i.e., 30.9.2013. The assessee failed to challenge the validity of the notice before the Assessing Officer and Commissioner of Income Tax (Appeals). The Income Tax Appellate Tribunal held that the initiation of proceedings and jurisdiction invoked by the Assessing Officer suffered from infirmity as the notice u/s 143(2) was issued beyond the statutory time limit. Consequently, the Tribunal ruled the impugned assessment order as invalid, rendering the issues raised on merits academic and not requiring adjudication.
The notice u/s 143(2) of the Income Tax Act was issued on 15.10.2013, beyond the prescribed time limit of six months from the end of the assessment year, i.e., 30.9.2013. The assessee failed to challenge the validity of the notice before the Assessing Officer and Commissioner of Income Tax (Appeals). The Income Tax Appellate Tribunal held that the initiation of proceedings and jurisdiction invoked by the Assessing Officer suffered from infirmity as the notice u/s 143(2) was issued beyond the statutory time limit. Consequently, the Tribunal ruled the impugned assessment order as invalid, rendering the issues raised on merits academic and not requiring adjudication.
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