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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This case deals with the applicability of Section 153, the limitation provision, to proceedings u/s 144C of the Income Tax Act. The key issues are whether the 11-month period envisaged u/s 144C should be in addition to the time limit prescribed u/s 153(1) read with Section 153(4), or whether it needs to be subsumed within the timelines stipulated u/s 153. The High Court observed that the Supreme Court is currently considering this issue arising from decisions of various High Courts, including the present case. The Revenue has issued circulars seeking adjournments in pending cases involving this issue before the Income Tax Appellate Tribunal, awaiting the Supreme Court's decision. Regarding interim relief, the High Court noted that assessees in similar cases have succeeded before the Madras and Delhi High Courts, and the Supreme Court has not stayed those orders setting aside the assessment orders. Consequently, the High Court continued the ad-interim order dated 28 June 2024 till the final disposal of this petition.
This case deals with the applicability of Section 153, the limitation provision, to proceedings u/s 144C of the Income Tax Act. The key issues are whether the 11-month period envisaged u/s 144C should be in addition to the time limit prescribed u/s 153(1) read with Section 153(4), or whether it needs to be subsumed within the timelines stipulated u/s 153. The High Court observed that the Supreme Court is currently considering this issue arising from decisions of various High Courts, including the present case. The Revenue has issued circulars seeking adjournments in pending cases involving this issue before the Income Tax Appellate Tribunal, awaiting the Supreme Court's decision. Regarding interim relief, the High Court noted that assessees in similar cases have succeeded before the Madras and Delhi High Courts, and the Supreme Court has not stayed those orders setting aside the assessment orders. Consequently, the High Court continued the ad-interim order dated 28 June 2024 till the final disposal of this petition.
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