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 that typographical error in address on notice under s.148 of IT Act does not invalidate reassessment proceedings. Taxpayer's claim for India-Singapore DTAA exemption without filing proper income tax return prompted IT Department's notice. Though taxpayer later filed manual return on 02.03.2022, department issued speaking order without considering CBDT Circular 3/2016. Court set aside speaking order dated 18.03.2022 and remanded matter, directing authorities to provide taxpayer reasonable opportunity to present case in light of CBDT Circular 3/2016. Mere address error on notice to Verizon Services Singapore Pte Ltd. (incorrectly sent to Visteon Tax Office, Michigan) does not render proceedings invalid.
HC determined that typographical error in address on notice under s.148 of IT Act does not invalidate reassessment proceedings. Taxpayer's claim for India-Singapore DTAA exemption without filing proper income tax return prompted IT Department's notice. Though taxpayer later filed manual return on 02.03.2022, department issued speaking order without considering CBDT Circular 3/2016. Court set aside speaking order dated 18.03.2022 and remanded matter, directing authorities to provide taxpayer reasonable opportunity to present case in light of CBDT Circular 3/2016. Mere address error on notice to Verizon Services Singapore Pte Ltd. (incorrectly sent to Visteon Tax Office, Michigan) does not render proceedings invalid.
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