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 assessing officer (AO) recorded vague reasons for reopening the assessment, merely stating that information was received about the assessee depositing cash of Rs. 10 lakhs or more in a savings bank account, without specifying the exact amount, bank account details, or date of transaction. The assessee contended that the reasons lacked credible information to form a belief that income had escaped assessment. The Appellate Tribunal held that the reasons recorded were general and vague, and the AO did not possess any credible information before reopening the assessment. Consequently, the reassessment proceedings u/s 143(3) read with Section 147 of the Act were quashed, and the assessee's appeal ground was allowed.
The assessing officer (AO) recorded vague reasons for reopening the assessment, merely stating that information was received about the assessee depositing cash of Rs. 10 lakhs or more in a savings bank account, without specifying the exact amount, bank account details, or date of transaction. The assessee contended that the reasons lacked credible information to form a belief that income had escaped assessment. The Appellate Tribunal held that the reasons recorded were general and vague, and the AO did not possess any credible information before reopening the assessment. Consequently, the reassessment proceedings u/s 143(3) read with Section 147 of the Act were quashed, and the assessee's appeal ground was allowed.
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