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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Introduction of block assessment provisions in cases of search u/s 132 and requisition u/s 132A for early finalization of search assessments, coordinated investigation, and reduction in multiplicity of proceedings. Block period consisting of previous years relevant to six assessment years preceding the previous year of search/requisition and period starting from 1st April of previous year of search/requisition till date of execution of last authorization. Regular assessments for block period to abate with one consolidated assessment. Assessment of total income including undisclosed income based on evidence found during search/requisition. Tax at 60% for block period without interest/penalty u/ss 234A/B/C and 270A. Penalty at 50% of tax payable on undisclosed income, nil if offered in return. Time limit of 12 months for block assessment, exclusion of 6 months from date of search to handing over of material. Evidence relating to international/specified domestic transactions after date of last authorization not considered for block period. Approval of higher authority required for notice/order. Section 144C not applicable.
Introduction of block assessment provisions in cases of search u/s 132 and requisition u/s 132A for early finalization of search assessments, coordinated investigation, and reduction in multiplicity of proceedings. Block period consisting of previous years relevant to six assessment years preceding the previous year of search/requisition and period starting from 1st April of previous year of search/requisition till date of execution of last authorization. Regular assessments for block period to abate with one consolidated assessment. Assessment of total income including undisclosed income based on evidence found during search/requisition. Tax at 60% for block period without interest/penalty u/ss 234A/B/C and 270A. Penalty at 50% of tax payable on undisclosed income, nil if offered in return. Time limit of 12 months for block assessment, exclusion of 6 months from date of search to handing over of material. Evidence relating to international/specified domestic transactions after date of last authorization not considered for block period. Approval of higher authority required for notice/order. Section 144C not applicable.
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