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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC upheld the extension of time limit for sale of attached immovable property u/r 68B of Income Tax Act's Second Schedule. Property was attached on 10.02.2021, with auction scheduled for 25.03.2021. Due to no bidders, Chief Commissioner validly extended sale period by one year to 31.03.2022 under second proviso to Rule 68B(1). Court rejected petitioner's argument regarding unauthorized extension and dismissed claim of exemption u/r 10 based on changed status as laborer. Extension order deemed valid as circumstances fell within permissible grounds for resale when highest bid falls below reserve price. Attachment and sale proceedings upheld as legally compliant within limitation period.
HC upheld the extension of time limit for sale of attached immovable property u/r 68B of Income Tax Act's Second Schedule. Property was attached on 10.02.2021, with auction scheduled for 25.03.2021. Due to no bidders, Chief Commissioner validly extended sale period by one year to 31.03.2022 under second proviso to Rule 68B(1). Court rejected petitioner's argument regarding unauthorized extension and dismissed claim of exemption u/r 10 based on changed status as laborer. Extension order deemed valid as circumstances fell within permissible grounds for resale when highest bid falls below reserve price. Attachment and sale proceedings upheld as legally compliant within limitation period.
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