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 quashed reassessment proceedings initiated under s. 147 where the AO had reopened assessment based solely on information from the Investigation Wing without independent application of mind. The Tribunal found that the assessee had fully disclosed all material facts during original assessment proceedings, substantiating the identity and creditworthiness of the loan creditor. The AO had already obtained information under s. 133(6) from Cambridge Financial Services Pvt. Ltd. during the original assessment completed under s. 143(3). Following Punia Capital (P.) Ltd., the ITAT held that reopening after four years requires failure to disclose material facts, which was absent in this case, as the AO relied merely on "reason to believe" without establishing any non-disclosure by the assessee.
The ITAT quashed reassessment proceedings initiated under s. 147 where the AO had reopened assessment based solely on information from the Investigation Wing without independent application of mind. The Tribunal found that the assessee had fully disclosed all material facts during original assessment proceedings, substantiating the identity and creditworthiness of the loan creditor. The AO had already obtained information under s. 133(6) from Cambridge Financial Services Pvt. Ltd. during the original assessment completed under s. 143(3). Following Punia Capital (P.) Ltd., the ITAT held that reopening after four years requires failure to disclose material facts, which was absent in this case, as the AO relied merely on "reason to believe" without establishing any non-disclosure by the assessee.
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