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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC upheld the assessment order made under section 143(3) read with section 144B. The assessee's contention regarding violation of Faceless Assessment Scheme due to non-provision of draft assessment order was rejected. Court determined that since it wasn't a best judgment assessment, no draft order was required. The sequential issuance of notices under sections 143(2) and 142(1) was deemed procedurally valid as both served the assessment purpose. The assessee's compliance with both notices negated claims of insufficient opportunity. The scrutiny assessment following section 144B procedures was found legally compliant, with no procedural violations warranting interference.
HC upheld the assessment order made under section 143(3) read with section 144B. The assessee's contention regarding violation of Faceless Assessment Scheme due to non-provision of draft assessment order was rejected. Court determined that since it wasn't a best judgment assessment, no draft order was required. The sequential issuance of notices under sections 143(2) and 142(1) was deemed procedurally valid as both served the assessment purpose. The assessee's compliance with both notices negated claims of insufficient opportunity. The scrutiny assessment following section 144B procedures was found legally compliant, with no procedural violations warranting interference.
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