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 s.147 against investment entities Top Most Investment, YK Securities, and Glider Investment. While Videocon Industries allegedly diverted bank financing to provide interest-free loans to these entities, the Court found no valid basis to conclude that income had escaped assessment in the recipients' hands. The reassessment notice under s.148A(b) and subsequent order under s.148A(d) failed to establish, even prima facie, how such fund diversion could lead to escaped income for the recipient entities. At most, this could have impacted interest deduction claims by Videocon, but provided no grounds for reopening assessment of the loan recipients.
HC quashed reassessment proceedings initiated under s.147 against investment entities Top Most Investment, YK Securities, and Glider Investment. While Videocon Industries allegedly diverted bank financing to provide interest-free loans to these entities, the Court found no valid basis to conclude that income had escaped assessment in the recipients' hands. The reassessment notice under s.148A(b) and subsequent order under s.148A(d) failed to establish, even prima facie, how such fund diversion could lead to escaped income for the recipient entities. At most, this could have impacted interest deduction claims by Videocon, but provided no grounds for reopening assessment of the loan recipients.
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