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 held that the reassessment order dated 12.05.2023 and subsequent proceedings were invalid as they were beyond the statutory limitation period prescribed u/s 153(2) of the Income Tax Act. For notices issued u/s 148 on or after 01.04.2019, the reassessment must be completed within twelve months from the end of the financial year in which the notice was issued. Since the notice was issued on 29.03.2021, the reassessment should have been completed by 31.03.2022. However, the reassessment order was passed on 12.05.2023, well beyond the twelve-month period, rendering it non-est and invalid. The Court rejected the Revenue's contention regarding the applicability of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, as the notice was issued within the extended limitation period under that Act. Consequently, the Court ruled in favor of the assessee.
The High Court held that the reassessment order dated 12.05.2023 and subsequent proceedings were invalid as they were beyond the statutory limitation period prescribed u/s 153(2) of the Income Tax Act. For notices issued u/s 148 on or after 01.04.2019, the reassessment must be completed within twelve months from the end of the financial year in which the notice was issued. Since the notice was issued on 29.03.2021, the reassessment should have been completed by 31.03.2022. However, the reassessment order was passed on 12.05.2023, well beyond the twelve-month period, rendering it non-est and invalid. The Court rejected the Revenue's contention regarding the applicability of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, as the notice was issued within the extended limitation period under that Act. Consequently, the Court ruled in favor of the assessee.
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