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 provisions relating to assessment and reassessment under the Act are proposed to be rationalized. Key amendments include: substituting sections 148 and 148A to provide procedure for issuing notice before assessment, reassessment or recomputation; defining 'information' to include survey findings after September 1, 2024; requiring approval for notice based on information u/s 135A scheme; providing time limits in section 149 for issuing notices u/ss 148A and 148, ranging from 3 years to 5 years and 3 months based on specific cases; substituting section 151 to specify authority for approvals; and amending section 152 for transitional provisions.
The provisions relating to assessment and reassessment under the Act are proposed to be rationalized. Key amendments include: substituting sections 148 and 148A to provide procedure for issuing notice before assessment, reassessment or recomputation; defining 'information' to include survey findings after September 1, 2024; requiring approval for notice based on information u/s 135A scheme; providing time limits in section 149 for issuing notices u/ss 148A and 148, ranging from 3 years to 5 years and 3 months based on specific cases; substituting section 151 to specify authority for approvals; and amending section 152 for transitional provisions.
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