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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The ITAT upheld the CIT(A)'s decision quashing the reassessment proceedings under s.147 initiated after four years. The Tribunal found that the AO's reasons for reopening were based on borrowed satisfaction without independent application of mind, constituting mere "reasons to suspect" rather than "reasons to believe." The AO failed to conduct preliminary inquiries by examining the assessee's and M/s Frankdeal Traders Pvt. Ltd.'s tax returns and audited financial statements before issuing the notice. Additionally, the AO erroneously alleged the assessee received accommodation entries during FY 2010-11, when the assessment order itself acknowledged these entries were received by M/s Frankdeal Traders up to FY 2008-09. This contradiction rendered the reassessment proceedings illegal and bad in law.
The ITAT upheld the CIT(A)'s decision quashing the reassessment proceedings under s.147 initiated after four years. The Tribunal found that the AO's reasons for reopening were based on borrowed satisfaction without independent application of mind, constituting mere "reasons to suspect" rather than "reasons to believe." The AO failed to conduct preliminary inquiries by examining the assessee's and M/s Frankdeal Traders Pvt. Ltd.'s tax returns and audited financial statements before issuing the notice. Additionally, the AO erroneously alleged the assessee received accommodation entries during FY 2010-11, when the assessment order itself acknowledged these entries were received by M/s Frankdeal Traders up to FY 2008-09. This contradiction rendered the reassessment proceedings illegal and bad in law.
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