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 quashed the reassessment proceedings initiated against the non-existent amalgamating company. Relying on the Supreme Court's decision in Maruti Suzuki India Ltd. and the Bombay High Court's judgment in Teleperformance Global Services Private Limited, the court held that once the amalgamating company ceased to exist due to the amalgamation scheme approved by the NCLT, the assessing officer lacked jurisdiction to proceed against a non-existent entity. Consequently, the impugned action u/s 148 of the Income Tax Act and the resultant assessment order were declared wholly without jurisdiction, non-est, and a nullity.
The High Court quashed the reassessment proceedings initiated against the non-existent amalgamating company. Relying on the Supreme Court's decision in Maruti Suzuki India Ltd. and the Bombay High Court's judgment in Teleperformance Global Services Private Limited, the court held that once the amalgamating company ceased to exist due to the amalgamation scheme approved by the NCLT, the assessing officer lacked jurisdiction to proceed against a non-existent entity. Consequently, the impugned action u/s 148 of the Income Tax Act and the resultant assessment order were declared wholly without jurisdiction, non-est, and a nullity.
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