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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Notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessment Officer (FAO) u/s 148A(b) for income escaping assessment is invalid. Faceless assessment scheme notified u/s 151A mandates automated allocation and faceless assessment u/s 144B. JAO lacked jurisdiction to issue notice outside faceless assessment procedure. Assessing Officer also failed to consider assessee's submission regarding project completion method while reopening assessment. Assessee's appeal allowed by High Court on grounds of invalidity of notice and non-consideration of submissions.
Notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessment Officer (FAO) u/s 148A(b) for income escaping assessment is invalid. Faceless assessment scheme notified u/s 151A mandates automated allocation and faceless assessment u/s 144B. JAO lacked jurisdiction to issue notice outside faceless assessment procedure. Assessing Officer also failed to consider assessee's submission regarding project completion method while reopening assessment. Assessee's appeal allowed by High Court on grounds of invalidity of notice and non-consideration of submissions.
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