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 quashed reassessment notices under Section 147 of the Income Tax Act, finding that the Assessing Officer failed to properly consider the Investigation Wing's report and mechanically issued notices without independent application of mind. The AO erroneously treated the total of debit and credit entries from the petitioner's books as escapement of income, without establishing any rational nexus between the transactions and alleged income escapement. Following precedents in Paresh Babubhai Bahalani and Bharatkumar Nihalchand Shah, the Court held that non-specific reasons without establishing nexus between transactions and income escapement invalidate reassessment jurisdiction. The proceedings were set aside due to lack of independent satisfaction in the recorded reasons.
The HC quashed reassessment notices under Section 147 of the Income Tax Act, finding that the Assessing Officer failed to properly consider the Investigation Wing's report and mechanically issued notices without independent application of mind. The AO erroneously treated the total of debit and credit entries from the petitioner's books as escapement of income, without establishing any rational nexus between the transactions and alleged income escapement. Following precedents in Paresh Babubhai Bahalani and Bharatkumar Nihalchand Shah, the Court held that non-specific reasons without establishing nexus between transactions and income escapement invalidate reassessment jurisdiction. The proceedings were set aside due to lack of independent satisfaction in the recorded reasons.
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