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 determined reassessment proceedings initiated under s.147/148 were invalid when based on materials discovered during search operation under s.132. Where incriminating evidence emerges from search, Revenue must proceed under s.153A/153C framework. The case originated from search of Shilpi Jewellers Pvt Ltd revealing accommodation entries through shell company Green Valley Gems Pvt Ltd. Court held that since foundation was search action yielding new materials, Revenue cannot bypass s.153A/153C by invoking s.147/148. Legislature intended these provisions to operate in distinct spheres, with s.153A containing non-obstante clause creating exception to regular reassessment under s.147. Notice under s.147 and subsequent actions declared without jurisdiction and void.
HC determined reassessment proceedings initiated under s.147/148 were invalid when based on materials discovered during search operation under s.132. Where incriminating evidence emerges from search, Revenue must proceed under s.153A/153C framework. The case originated from search of Shilpi Jewellers Pvt Ltd revealing accommodation entries through shell company Green Valley Gems Pvt Ltd. Court held that since foundation was search action yielding new materials, Revenue cannot bypass s.153A/153C by invoking s.147/148. Legislature intended these provisions to operate in distinct spheres, with s.153A containing non-obstante clause creating exception to regular reassessment under s.147. Notice under s.147 and subsequent actions declared without jurisdiction and void.
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