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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ITAT quashed assessment order made under section 143(3) for AY 2021-22, declaring it void ab initio. The assessment, based on materials from search operations conducted on Hans Group, should have been processed under section 153C rather than regular assessment under 143(3). Following first proviso to section 153C, AY 2023-24 being search year, assessments for six prior years (2017-18 to 2022-23) required completion under 153C. Despite recording satisfaction note under 153C, AO's completion of assessment under 143(3) was held legally impermissible. Tribunal relied on similar precedent from Mukul Rani Thakur case involving identical Hans Group search circumstances.
ITAT quashed assessment order made under section 143(3) for AY 2021-22, declaring it void ab initio. The assessment, based on materials from search operations conducted on Hans Group, should have been processed under section 153C rather than regular assessment under 143(3). Following first proviso to section 153C, AY 2023-24 being search year, assessments for six prior years (2017-18 to 2022-23) required completion under 153C. Despite recording satisfaction note under 153C, AO's completion of assessment under 143(3) was held legally impermissible. Tribunal relied on similar precedent from Mukul Rani Thakur case involving identical Hans Group search circumstances.
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