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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ITAT determined assessment order under sections 263/143(3)/147 was time-barred and invalid. Though AO passed order on 30.12.2015, it was served to assessee on 05.01.2016, beyond statutory deadline of 31.12.2015 per Section 153. AO's subsequent clarification citing 30.12.2015 as order date conflicted with claimed execution date of 31.12.2015. Despite intervening weekend holidays, failure to serve within limitation period rendered order non-est and void ab initio. Tribunal upheld assessee's appeal, declaring assessment proceedings legally invalid due to service beyond prescribed limitation period.
ITAT determined assessment order under sections 263/143(3)/147 was time-barred and invalid. Though AO passed order on 30.12.2015, it was served to assessee on 05.01.2016, beyond statutory deadline of 31.12.2015 per Section 153. AO's subsequent clarification citing 30.12.2015 as order date conflicted with claimed execution date of 31.12.2015. Despite intervening weekend holidays, failure to serve within limitation period rendered order non-est and void ab initio. Tribunal upheld assessee's appeal, declaring assessment proceedings legally invalid due to service beyond prescribed limitation period.
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