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 held that erroneous attachment of another taxpayer's information to section 148 notice due to inadvertence does not invalidate reassessment proceedings. However, the subsequent order dated 03.02.2025 was deemed unsustainable as it overlooked this apparent error, indicating lack of proper consideration of petitioner's objections. Court directed revenue authorities to rectify notice by providing correct Insight Portal information and Specified Authority approval within one week, allowing petitioner to file fresh objections. The procedural error was treated as rectifiable rather than fatal, balancing administrative efficiency with taxpayer rights under reassessment provisions.
HC held that erroneous attachment of another taxpayer's information to section 148 notice due to inadvertence does not invalidate reassessment proceedings. However, the subsequent order dated 03.02.2025 was deemed unsustainable as it overlooked this apparent error, indicating lack of proper consideration of petitioner's objections. Court directed revenue authorities to rectify notice by providing correct Insight Portal information and Specified Authority approval within one week, allowing petitioner to file fresh objections. The procedural error was treated as rectifiable rather than fatal, balancing administrative efficiency with taxpayer rights under reassessment provisions.
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