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 determined the reassessment notice issued on 30.07.2022 was time-barred under Section 149(1). While TOLA provided AO twenty-nine days limitation period from 01.06.2021, and considering the two-week response time given to assessee under Section 148A(b), the limitation period expired on 12.07.2022. The court found the notice issued on 30.07.2022 was beyond prescribed limitation. The fourth proviso to Section 149 was inapplicable as AO had sufficient time to pass order under Section 148A(d). The HC quashed both the order under Section 148A(d) and notice under Section 148, ruling in assessee's favor due to the procedural time-bar.
HC determined the reassessment notice issued on 30.07.2022 was time-barred under Section 149(1). While TOLA provided AO twenty-nine days limitation period from 01.06.2021, and considering the two-week response time given to assessee under Section 148A(b), the limitation period expired on 12.07.2022. The court found the notice issued on 30.07.2022 was beyond prescribed limitation. The fourth proviso to Section 149 was inapplicable as AO had sufficient time to pass order under Section 148A(d). The HC quashed both the order under Section 148A(d) and notice under Section 148, ruling in assessee's favor due to the procedural time-bar.
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