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 quashed reassessment proceedings initiated under Section 147 after expiry of 4-year limitation period. Court found no failure by assessee to disclose material facts fully and truly, as required by first proviso to Section 147. Information relied upon for reopening was already available in documents filed with return and during original assessment. Where matter was previously examined during assessment after raising queries, allowing reassessment would amount to impermissible review power. Reopening notice held invalid as reasons recorded failed to specify any non-disclosure of material facts by assessee.
HC quashed reassessment proceedings initiated under Section 147 after expiry of 4-year limitation period. Court found no failure by assessee to disclose material facts fully and truly, as required by first proviso to Section 147. Information relied upon for reopening was already available in documents filed with return and during original assessment. Where matter was previously examined during assessment after raising queries, allowing reassessment would amount to impermissible review power. Reopening notice held invalid as reasons recorded failed to specify any non-disclosure of material facts by assessee.
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