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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The High Court upheld the validity of the Assessing Officer's jurisdiction to frame the assessment order u/s 144. Even if the case was not liable for compulsory scrutiny per CBDT guidelines, it fell within Section 143(2) allowing the AO to issue notice and proceed with assessment u/s 144 if income had escaped assessment. The AO's power u/s 143(2) is statutory and cannot be curtailed by CBDT instructions, as that would require the AO to dispose of a case in a manner not prescribed by statute. The ITAT order upholding the assessment u/s 144 was found to have no illegality or infirmity.
The High Court upheld the validity of the Assessing Officer's jurisdiction to frame the assessment order u/s 144. Even if the case was not liable for compulsory scrutiny per CBDT guidelines, it fell within Section 143(2) allowing the AO to issue notice and proceed with assessment u/s 144 if income had escaped assessment. The AO's power u/s 143(2) is statutory and cannot be curtailed by CBDT instructions, as that would require the AO to dispose of a case in a manner not prescribed by statute. The ITAT order upholding the assessment u/s 144 was found to have no illegality or infirmity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
