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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Notices issued u/ss 84 and 27(1)(a) of the Tamil Nadu Value Added Tax Act, 2006 were valid. The time limitation for revising assessment orders is not an issue if a notice is issued in time. The High Court had previously dealt with a similar case involving Section 27. According to the proviso to Section 22(2), assessment years were deemed completed on 30.06.2012. Any revision proceedings had to be completed within six years for deemed assessments u/s 27. Mentioning the wrong provision or not mentioning it does not invalidate an order if the authority had requisite jurisdiction. The 23.07.2014 notices, though erroneously mentioning Section 84, were intended for revision u/s 27(1)(a). The assessments completed on 04.01.2021, 31.12.2020, and 07.01.2021 were within the limitation period prescribed u/s 27(1)(a). The writ petitions were dismissed.
Notices issued u/ss 84 and 27(1)(a) of the Tamil Nadu Value Added Tax Act, 2006 were valid. The time limitation for revising assessment orders is not an issue if a notice is issued in time. The High Court had previously dealt with a similar case involving Section 27. According to the proviso to Section 22(2), assessment years were deemed completed on 30.06.2012. Any revision proceedings had to be completed within six years for deemed assessments u/s 27. Mentioning the wrong provision or not mentioning it does not invalidate an order if the authority had requisite jurisdiction. The 23.07.2014 notices, though erroneously mentioning Section 84, were intended for revision u/s 27(1)(a). The assessments completed on 04.01.2021, 31.12.2020, and 07.01.2021 were within the limitation period prescribed u/s 27(1)(a). The writ petitions were dismissed.
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