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 reassessment notice u/s 147, holding that the Assessing Officer failed to form a valid reason to believe that income had escaped assessment. The AO merely brushed aside the assessee's objections without considering them in detail. The AO made vague observations about transactions not reflected in the Demat account but did not address the specific details provided by the assessee in the objections. The Court ruled that the AO cannot validly form a reason to believe without properly examining the assessee's objections, rendering the reassessment notice untenable. The decision was in favor of the assessee.
The High Court quashed the reassessment notice u/s 147, holding that the Assessing Officer failed to form a valid reason to believe that income had escaped assessment. The AO merely brushed aside the assessee's objections without considering them in detail. The AO made vague observations about transactions not reflected in the Demat account but did not address the specific details provided by the assessee in the objections. The Court ruled that the AO cannot validly form a reason to believe without properly examining the assessee's objections, rendering the reassessment notice untenable. The decision was in favor of the assessee.
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