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 quashed reassessment proceedings initiated under s.147 regarding alleged undervaluation of shares of TREPL. AO's attempt to reopen assessment was based on the value of immovable property (Friends Colony) held by TREPL, an issue previously examined in earlier reassessment proceedings. Petitioner had already demonstrated through audited financial statements that TREPL owned only two floors of the property, which AO had accepted. The court found that reopening the same issue violated procedural requirements under s.148A(d), as AO failed to consider petitioner's response to s.148A(b) notice and the existing record. Since the information was previously scrutinized and no credible contradictory evidence existed, reassessment was held invalid.
HC quashed reassessment proceedings initiated under s.147 regarding alleged undervaluation of shares of TREPL. AO's attempt to reopen assessment was based on the value of immovable property (Friends Colony) held by TREPL, an issue previously examined in earlier reassessment proceedings. Petitioner had already demonstrated through audited financial statements that TREPL owned only two floors of the property, which AO had accepted. The court found that reopening the same issue violated procedural requirements under s.148A(d), as AO failed to consider petitioner's response to s.148A(b) notice and the existing record. Since the information was previously scrutinized and no credible contradictory evidence existed, reassessment was held invalid.
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