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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AO solely relied on unspecified information categorized as 'high risk transactions' of unsecured loans without giving specific details of lenders, amounting to bald allegations. No definitive link or adverse document was present at the time of forming belief. Mere identification of transactions as 'high risk' cannot provide cause for reopening assessment. The reasons recorded give an impression of 'reason to suspect' rather than 'reason to believe' escapement of income as required u/s 147. The purported 'belief' is premised on vague grounds, failing the test of 'reason to believe'. ITAT allowed assessee's appeal.
AO solely relied on unspecified information categorized as 'high risk transactions' of unsecured loans without giving specific details of lenders, amounting to bald allegations. No definitive link or adverse document was present at the time of forming belief. Mere identification of transactions as 'high risk' cannot provide cause for reopening assessment. The reasons recorded give an impression of 'reason to suspect' rather than 'reason to believe' escapement of income as required u/s 147. The purported 'belief' is premised on vague grounds, failing the test of 'reason to believe'. ITAT allowed assessee's appeal.
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