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 examined the validity of reopening an assessment and invoking the extended period of limitation to add deemed dividend u/s 2(22)(e) of the Income Tax Act. The assessee had purchased a property, receiving the entire amount from a company where the assessee held 29% shares. The court held that the revenue authorities sought to add a sum as "deemed income" through the reassessment order, which was unsuccessfully challenged by the assessee. However, the Tribunal reversed the Commissioner's order affirming the reassessment. The court observed that the department's attempt was to merely include an additional amount over the sum subject to the earlier assessment order, which stood deleted. Considering the appeal's withdrawal, the issue was construed as answered against the revenue and in favor of the assessee, implying a lack of tangible material for reopening the assessment.
The High Court examined the validity of reopening an assessment and invoking the extended period of limitation to add deemed dividend u/s 2(22)(e) of the Income Tax Act. The assessee had purchased a property, receiving the entire amount from a company where the assessee held 29% shares. The court held that the revenue authorities sought to add a sum as "deemed income" through the reassessment order, which was unsuccessfully challenged by the assessee. However, the Tribunal reversed the Commissioner's order affirming the reassessment. The court observed that the department's attempt was to merely include an additional amount over the sum subject to the earlier assessment order, which stood deleted. Considering the appeal's withdrawal, the issue was construed as answered against the revenue and in favor of the assessee, implying a lack of tangible material for reopening the assessment.
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