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 dismissed writ petition challenging reopening of assessment under s.147. Petitioner failed to provide crucial attachments and documentary evidence to support claims regarding prior disclosure during regular assessment. Court held it could not exercise extraordinary jurisdiction to investigate factual matters without complete documentation. While audit objection formed basis for reopening, Court refrained from deciding broader legal question of post-amendment reopening validity based on audit opinions. Petitioner retains liberty to challenge validity of reassessment before Appellate Authority after final order under s.148. Matter involves factual verification inappropriate for writ proceedings.
HC dismissed writ petition challenging reopening of assessment under s.147. Petitioner failed to provide crucial attachments and documentary evidence to support claims regarding prior disclosure during regular assessment. Court held it could not exercise extraordinary jurisdiction to investigate factual matters without complete documentation. While audit objection formed basis for reopening, Court refrained from deciding broader legal question of post-amendment reopening validity based on audit opinions. Petitioner retains liberty to challenge validity of reassessment before Appellate Authority after final order under s.148. Matter involves factual verification inappropriate for writ proceedings.
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