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 reopening of assessment was invalid. Despite the amendment made in 1998 to Section 147 of the Act, reassessment proceedings cannot be initiated based on a change of opinion. The Assessing Officer (AO) had previously considered the issue of deduction u/s 54B and formed an opinion, albeit without recording reasons. The explanation provided by the petitioner was accepted, and the deduction u/s 54B was allowed. Consequently, the notice issued u/s 148 for the assessment year 2009-2010 and the order rejecting the objections were quashed by the High Court.
The High Court held that the reopening of assessment was invalid. Despite the amendment made in 1998 to Section 147 of the Act, reassessment proceedings cannot be initiated based on a change of opinion. The Assessing Officer (AO) had previously considered the issue of deduction u/s 54B and formed an opinion, albeit without recording reasons. The explanation provided by the petitioner was accepted, and the deduction u/s 54B was allowed. Consequently, the notice issued u/s 148 for the assessment year 2009-2010 and the order rejecting the objections were quashed by the High Court.
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