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 HC upheld the reopening of assessment beyond the four-year limitation period, finding the appellant had claimed a deduction twice and failed to make full and true disclosure of material facts during original assessment proceedings. The AO correctly exercised jurisdiction under s. 147 after discovering the false claim. The court dismissed the writ appeal, noting that the appellant had already pursued alternate remedy by filing an appeal before the CIT(A) on the same issues after the writ petition's dismissal. The HC confirmed the appellant could address the merits of reopening before the CIT(A), rejecting the appellant's contention that no double claim existed.
The HC upheld the reopening of assessment beyond the four-year limitation period, finding the appellant had claimed a deduction twice and failed to make full and true disclosure of material facts during original assessment proceedings. The AO correctly exercised jurisdiction under s. 147 after discovering the false claim. The court dismissed the writ appeal, noting that the appellant had already pursued alternate remedy by filing an appeal before the CIT(A) on the same issues after the writ petition's dismissal. The HC confirmed the appellant could address the merits of reopening before the CIT(A), rejecting the appellant's contention that no double claim existed.
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