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 allowed the petition and set aside the impugned reassessment notice and subsequent proceedings. The AO's satisfaction note for invoking reassessment proceedings u/s 153C of the Income Tax Act was held to be barred by limitation, as it was prepared beyond the prescribed 10-year period from the relevant assessment year. The HC concluded that the notice was invalid and quashed the reassessment proceedings initiated against the petitioner.
The HC allowed the petition and set aside the impugned reassessment notice and subsequent proceedings. The AO's satisfaction note for invoking reassessment proceedings u/s 153C of the Income Tax Act was held to be barred by limitation, as it was prepared beyond the prescribed 10-year period from the relevant assessment year. The HC concluded that the notice was invalid and quashed the reassessment proceedings initiated against the petitioner.
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