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 quashed reassessment notice under s.147/148 of Income Tax Act concerning interest-free loans to related entities and interest claims on borrowed funds. The assessee had made complete disclosure in original returns filed on 29.09.2013 including balance sheet and P&L statements. RTI documents revealed AO had formed opinion on interest-free group loans during original assessment concluded on 29.06.2015. Court found no failure by assessee to disclose material facts necessary for assessment. The subsequent reopening was unwarranted as AO had previously justified original assessment conclusions in response to audit objections. Notice dated 28.03.2021 and speaking order dated 29.07.2021 were held unsustainable.
HC quashed reassessment notice under s.147/148 of Income Tax Act concerning interest-free loans to related entities and interest claims on borrowed funds. The assessee had made complete disclosure in original returns filed on 29.09.2013 including balance sheet and P&L statements. RTI documents revealed AO had formed opinion on interest-free group loans during original assessment concluded on 29.06.2015. Court found no failure by assessee to disclose material facts necessary for assessment. The subsequent reopening was unwarranted as AO had previously justified original assessment conclusions in response to audit objections. Notice dated 28.03.2021 and speaking order dated 29.07.2021 were held unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
