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 quashed the reopening notice for AY 2015-16. The AO mechanically reopened assessment without independent application of mind, merely relying on information from DGIT about alleged non-genuine derivative trades. The assessee had disclosed profits from futures/options trading which were accepted in regular assessment. Reopening based on change of opinion that such profits were from derivatives is impermissible. The AO failed to form an independent reasonable belief of income escaping assessment after examining assessee's records. Mere borrowed satisfaction from third-party information cannot justify reassessment without verifying assessee's specific facts.
The HC quashed the reopening notice for AY 2015-16. The AO mechanically reopened assessment without independent application of mind, merely relying on information from DGIT about alleged non-genuine derivative trades. The assessee had disclosed profits from futures/options trading which were accepted in regular assessment. Reopening based on change of opinion that such profits were from derivatives is impermissible. The AO failed to form an independent reasonable belief of income escaping assessment after examining assessee's records. Mere borrowed satisfaction from third-party information cannot justify reassessment without verifying assessee's specific facts.
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