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 the faceless assessment order due to procedural violations under Section 144B. After issuing notices under Section 148 and 143(2), the Assessing Officer proceeded directly to finalize assessment without following mandatory show cause procedure when variations prejudicial to assessee were proposed. This constituted a breach of natural justice principles and statutory requirements under the Faceless Assessment Scheme. The absence of proper show cause notice before making adverse modifications rendered the assessment void. Court set aside the assessment order, demand notice under Section 156, and penalty notice under Section 271(1)(C) read with Section 274, remanding the matter back to the AO for fresh consideration following proper procedure.
HC quashed the faceless assessment order due to procedural violations under Section 144B. After issuing notices under Section 148 and 143(2), the Assessing Officer proceeded directly to finalize assessment without following mandatory show cause procedure when variations prejudicial to assessee were proposed. This constituted a breach of natural justice principles and statutory requirements under the Faceless Assessment Scheme. The absence of proper show cause notice before making adverse modifications rendered the assessment void. Court set aside the assessment order, demand notice under Section 156, and penalty notice under Section 271(1)(C) read with Section 274, remanding the matter back to the AO for fresh consideration following proper procedure.
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