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 beyond 4 years under s.147 on multiple grounds. Issues raised were identical to prior s.263 revision proceedings where PCIT had directed fresh assessment. Reopening on same grounds was unjustified, particularly after 4-year limitation. AO failed to specify undisclosed material facts while admitting review was based on existing records. Officer's claim of predecessor's inadvertent relief contradicted allegation of non-disclosure by assessee. Re-examination of issues already addressed in assessment order following s.263 proceedings amounts to impermissible change of opinion and review. Third proviso to s.147 bars such proceedings when matters were previously examined under s.263. Petition allowed in assessee's favor.
HC quashed reassessment proceedings initiated beyond 4 years under s.147 on multiple grounds. Issues raised were identical to prior s.263 revision proceedings where PCIT had directed fresh assessment. Reopening on same grounds was unjustified, particularly after 4-year limitation. AO failed to specify undisclosed material facts while admitting review was based on existing records. Officer's claim of predecessor's inadvertent relief contradicted allegation of non-disclosure by assessee. Re-examination of issues already addressed in assessment order following s.263 proceedings amounts to impermissible change of opinion and review. Third proviso to s.147 bars such proceedings when matters were previously examined under s.263. Petition allowed in assessee's favor.
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