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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The High Court quashed the reopening notice issued by the Assessing Officer u/s 148 for reassessment beyond the period of four years. The assessee had filed returns disclosing long-term capital gains from the sale of land, which was subjected to scrutiny during the regular assessment. The Court held that the Assessing Officer lacked jurisdiction to reopen the assessment as there was no failure on the assessee's part to disclose fully and truly all material facts relevant for the assessment. The reasons recorded by the Assessing Officer were incorrect, based on assumptions and presumptions without any basis. The Court ruled that the reopening notice was impermissibly issued based on an audit objection, without any fresh tangible information available to the Assessing Officer to justify reopening an assessment already completed u/s 143(3) after more than four years. Consequently, the impugned notice u/s 148 was quashed in favor of the assessee.
The High Court quashed the reopening notice issued by the Assessing Officer u/s 148 for reassessment beyond the period of four years. The assessee had filed returns disclosing long-term capital gains from the sale of land, which was subjected to scrutiny during the regular assessment. The Court held that the Assessing Officer lacked jurisdiction to reopen the assessment as there was no failure on the assessee's part to disclose fully and truly all material facts relevant for the assessment. The reasons recorded by the Assessing Officer were incorrect, based on assumptions and presumptions without any basis. The Court ruled that the reopening notice was impermissibly issued based on an audit objection, without any fresh tangible information available to the Assessing Officer to justify reopening an assessment already completed u/s 143(3) after more than four years. Consequently, the impugned notice u/s 148 was quashed in favor of the assessee.
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