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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Notices issued u/s 148 by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) were held invalid due to lack of jurisdiction, as per Section 151A and Central Government notification dated March 29, 2022. Relying on Hexaware Technologies Ltd. decision, High Court ruled that JAO lacked authority to issue impugned notices, rendering them illegal and invalid. Petition was allowed in favor of assessee.
Notices issued u/s 148 by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) were held invalid due to lack of jurisdiction, as per Section 151A and Central Government notification dated March 29, 2022. Relying on Hexaware Technologies Ltd. decision, High Court ruled that JAO lacked authority to issue impugned notices, rendering them illegal and invalid. Petition was allowed in favor of assessee.
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