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 HC held that the reassessment order was a detailed one based on appreciation of documents and rival submissions, not a cryptic order. As an effective alternative remedy of appeal u/s 246A of the Income Tax Act, 1961 is available, it would not be proper for the HC to exercise its extraordinary jurisdiction under Article 226 against the reassessment proceedings. However, the petitioner is free to avail the statutory alternative remedy.
The HC held that the reassessment order was a detailed one based on appreciation of documents and rival submissions, not a cryptic order. As an effective alternative remedy of appeal u/s 246A of the Income Tax Act, 1961 is available, it would not be proper for the HC to exercise its extraordinary jurisdiction under Article 226 against the reassessment proceedings. However, the petitioner is free to avail the statutory alternative remedy.
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