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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Reopening of assessment under s.147 challenged on grounds of invalid notice under s.143(2) and "change of opinion." ITAT held notice under s.143(2) was valid as return was e-verified on 24.10.2019 and notice issued on 05.11.2019 complied with statutory requirements. However, reopening was quashed as it was based on identical facts available during original assessment under s.143(3), constituting mere change of opinion by successor AO without discovery of new material. Following Kelvinator precedent, reassessment proceedings initiated without fresh evidence were deemed impermissible. Appeal partly allowed in assessee's favor on the substantive ground of invalid reopening, though procedural challenge regarding notice was rejected.
Reopening of assessment under s.147 challenged on grounds of invalid notice under s.143(2) and "change of opinion." ITAT held notice under s.143(2) was valid as return was e-verified on 24.10.2019 and notice issued on 05.11.2019 complied with statutory requirements. However, reopening was quashed as it was based on identical facts available during original assessment under s.143(3), constituting mere change of opinion by successor AO without discovery of new material. Following Kelvinator precedent, reassessment proceedings initiated without fresh evidence were deemed impermissible. Appeal partly allowed in assessee's favor on the substantive ground of invalid reopening, though procedural challenge regarding notice was rejected.
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