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 Appellate Tribunal (ITAT) addressed the validity of an assessment order passed u/s 153C, considering the issue of limitation. The assessee raised the plea that the assessment year 2004-05 was beyond the six-year block period for assessment u/s 153C. Although the order bore the date 30.12.2011, it was issued and dispatched on 02.01.2012 as per the post office report. Since the assessee raised this plea for the first time during the appeal hearing, the ITAT remanded the issue to the Assessing Officer for proper verification and adjudication, along with other set-aside issues. The appeal was allowed for statistical purposes.
The Appellate Tribunal (ITAT) addressed the validity of an assessment order passed u/s 153C, considering the issue of limitation. The assessee raised the plea that the assessment year 2004-05 was beyond the six-year block period for assessment u/s 153C. Although the order bore the date 30.12.2011, it was issued and dispatched on 02.01.2012 as per the post office report. Since the assessee raised this plea for the first time during the appeal hearing, the ITAT remanded the issue to the Assessing Officer for proper verification and adjudication, along with other set-aside issues. The appeal was allowed for statistical purposes.
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