Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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The case pertains to the reopening of assessment u/s 147, where the reasons recorded were based on audit objections raised by the internal audit party regarding underassessment of income and default determination of Transfer Pricing (TP) Adjustment. The Transfer Pricing Officer (TPO) made a markup of 12% on direct costs, but the audit objection suggested reducing it to 9.17% after accounting for foreign exchange risk of 1%. The court held that the TPO's order was detailed, considering all aspects, and the audit objection amounted to a mere change of opinion without any failure on the part of the petitioner to disclose material facts. Since the impugned notice was issued beyond four years, the respondent could not have assumed jurisdiction based on audit objections. Regarding the reduced exchange gain on sale of shares, the assessee made full disclosure, and there was no failure to disclose material facts, preventing the respondent from reopening the assessment u/s 147's proviso. The decision was in favor of the assessee.
The case pertains to the reopening of assessment u/s 147, where the reasons recorded were based on audit objections raised by the internal audit party regarding underassessment of income and default determination of Transfer Pricing (TP) Adjustment. The Transfer Pricing Officer (TPO) made a markup of 12% on direct costs, but the audit objection suggested reducing it to 9.17% after accounting for foreign exchange risk of 1%. The court held that the TPO's order was detailed, considering all aspects, and the audit objection amounted to a mere change of opinion without any failure on the part of the petitioner to disclose material facts. Since the impugned notice was issued beyond four years, the respondent could not have assumed jurisdiction based on audit objections. Regarding the reduced exchange gain on sale of shares, the assessee made full disclosure, and there was no failure to disclose material facts, preventing the respondent from reopening the assessment u/s 147's proviso. The decision was in favor of the assessee.
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