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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
HC determined the reopening assessment under s.147 was invalid as it constituted mere change of opinion. The AO's reliance on cash deposit information from Insight Portal did not qualify as fresh material since this data was previously examined during regular assessment. The court found no legitimate basis for the AO's "reason to believe" income had escaped assessment, as the information lacked new elements establishing a live nexus. Consequently, the s.148 notice for AY 2017-18 was quashed for lack of jurisdiction. The ruling emphasizes that reassessment cannot be initiated based on reexamination of existing material already considered during original assessment proceedings.
HC determined the reopening assessment under s.147 was invalid as it constituted mere change of opinion. The AO's reliance on cash deposit information from Insight Portal did not qualify as fresh material since this data was previously examined during regular assessment. The court found no legitimate basis for the AO's "reason to believe" income had escaped assessment, as the information lacked new elements establishing a live nexus. Consequently, the s.148 notice for AY 2017-18 was quashed for lack of jurisdiction. The ruling emphasizes that reassessment cannot be initiated based on reexamination of existing material already considered during original assessment proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
