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" ?
ITAT invalidated assessments under s.153C read with s.153A for AYs 2011-12 and 2012-13. The AO recorded satisfaction note on 25.09.2018, making AY 2019-20 the relevant search assessment year. The years under dispute fell outside jurisdictional scope of revision proceedings. The satisfaction note for block period AYs 2011-12 to 2017-18 failed to establish document-wise correlation with assessment years in question, lacking essential elements required under s.153C. The Tribunal quashed assessment orders made under s.153A(1)(b) and allowed assessee's appeal, finding fundamental jurisdictional defect in proceedings initiated based on inadequate satisfaction note.
ITAT invalidated assessments under s.153C read with s.153A for AYs 2011-12 and 2012-13. The AO recorded satisfaction note on 25.09.2018, making AY 2019-20 the relevant search assessment year. The years under dispute fell outside jurisdictional scope of revision proceedings. The satisfaction note for block period AYs 2011-12 to 2017-18 failed to establish document-wise correlation with assessment years in question, lacking essential elements required under s.153C. The Tribunal quashed assessment orders made under s.153A(1)(b) and allowed assessee's appeal, finding fundamental jurisdictional defect in proceedings initiated based on inadequate satisfaction note.
Note: It is a system-generated summary and is for quick reference only.