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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AO reopened assessment on basis of difference between market value and registration value of property, assuming petitioner was owner. Petitioner argued section 50C inapplicable as not owner, section 43CA not in force that year. HC held AO failed to consider petitioner's objections regarding no escapement of income due to value difference being non-taxable. No information with AO showing direct nexus with escaped income alleged. Petitioner disclosed all material facts, so AO lacked jurisdiction u/s 147 proviso to reopen beyond 4 years. Petition allowed.
AO reopened assessment on basis of difference between market value and registration value of property, assuming petitioner was owner. Petitioner argued section 50C inapplicable as not owner, section 43CA not in force that year. HC held AO failed to consider petitioner's objections regarding no escapement of income due to value difference being non-taxable. No information with AO showing direct nexus with escaped income alleged. Petitioner disclosed all material facts, so AO lacked jurisdiction u/s 147 proviso to reopen beyond 4 years. Petition allowed.
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