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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Reopening of assessment u/s 147 was invalid as there was no failure by the assessee to disclose material facts. The assessment was reopened solely based on information that some parties from whom the assessee made purchases were non-filers of GST. However, the purchases were already examined and accepted in the original assessment order u/s 143(3). The Appellate Tribunal held that there was no document or evidence revealing any income chargeable to tax that had escaped assessment. Since the time limit for reopening had expired and the first proviso to Section 147 was not satisfied, the reopening itself was bad in law and quashed. The assessment order was quashed, and the assessee's appeal was allowed.
Reopening of assessment u/s 147 was invalid as there was no failure by the assessee to disclose material facts. The assessment was reopened solely based on information that some parties from whom the assessee made purchases were non-filers of GST. However, the purchases were already examined and accepted in the original assessment order u/s 143(3). The Appellate Tribunal held that there was no document or evidence revealing any income chargeable to tax that had escaped assessment. Since the time limit for reopening had expired and the first proviso to Section 147 was not satisfied, the reopening itself was bad in law and quashed. The assessment order was quashed, and the assessee's appeal was allowed.
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