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 ruled that Black Money Act proceedings cannot continue where income was declared and settled under Chapter XIX-A of Income Tax Act prior to Black Money Act implementation. The assessee filed returns on 21.05.2015, before the Black Money Act came into effect on 01.07.2015. The settlement under Chapter XIX-A was deemed valid and binding, making subsequent notices under Section 10(1) of Black Money Act untenable. HC emphasized that the Black Money Act's implementation does not invalidate prior settlements under Income Tax Act, supported by CBDT Circular No.12/2015. The settlement commission's order dated 26.08.2022 was upheld as final, effectively barring parallel proceedings under Black Money Act.
HC ruled that Black Money Act proceedings cannot continue where income was declared and settled under Chapter XIX-A of Income Tax Act prior to Black Money Act implementation. The assessee filed returns on 21.05.2015, before the Black Money Act came into effect on 01.07.2015. The settlement under Chapter XIX-A was deemed valid and binding, making subsequent notices under Section 10(1) of Black Money Act untenable. HC emphasized that the Black Money Act's implementation does not invalidate prior settlements under Income Tax Act, supported by CBDT Circular No.12/2015. The settlement commission's order dated 26.08.2022 was upheld as final, effectively barring parallel proceedings under Black Money Act.
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