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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HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to disclose material facts fully and truly during original assessment. The reopening attempt by successor AO on previously decided issues amounted to improper exercise of revisionary powers. The court held that mere change of opinion cannot justify reopening beyond 4-year limitation period without new material facts. The Revenue's attempt to reopen assessment based on different interpretation of same facts was deemed invalid, as original assessment decision had considered and accepted assessee's claims. Decision affirmed CIT(A)'s order quashing the reassessment notice.
HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to disclose material facts fully and truly during original assessment. The reopening attempt by successor AO on previously decided issues amounted to improper exercise of revisionary powers. The court held that mere change of opinion cannot justify reopening beyond 4-year limitation period without new material facts. The Revenue's attempt to reopen assessment based on different interpretation of same facts was deemed invalid, as original assessment decision had considered and accepted assessee's claims. Decision affirmed CIT(A)'s order quashing the reassessment notice.
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