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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
In light of the search material, the course of action should have been taken u/s 153C instead of Section 148. The Assessing Officer erred in invoking reassessment proceedings u/s 147, rendering the subsequent actions without jurisdiction, as per the judgments in Sri Dinakara Suvarna and Badal Prakash Jindal. The revenue failed to prove that the Assessing Officer's order was erroneous and prejudicial, as the PCIT could not establish non-application of mind, considering the Assessing Officer had examined the order of Kapil Romanna. Mere allegation of passing an order without application of mind is insufficient to invoke Section 263. The PCIT's findings and observations are infirm and perverse. Consequently, invoking Section 263 is not a fit case, and the order passed under it is quashed, favoring the assessee.
In light of the search material, the course of action should have been taken u/s 153C instead of Section 148. The Assessing Officer erred in invoking reassessment proceedings u/s 147, rendering the subsequent actions without jurisdiction, as per the judgments in Sri Dinakara Suvarna and Badal Prakash Jindal. The revenue failed to prove that the Assessing Officer's order was erroneous and prejudicial, as the PCIT could not establish non-application of mind, considering the Assessing Officer had examined the order of Kapil Romanna. Mere allegation of passing an order without application of mind is insufficient to invoke Section 263. The PCIT's findings and observations are infirm and perverse. Consequently, invoking Section 263 is not a fit case, and the order passed under it is quashed, favoring the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
