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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT quashed the assessment order passed under section 143(3) dated 27/03/2015. The Tribunal held that since the satisfaction note for initiating proceedings under section 153C was recorded on 10/10/2024, the assessment year relevant to the search was AY 2015-16, with the preceding six years being AY 2009-10 to 2014-15. As the impugned AY 2013-14 fell within this block period, the assessment should have been completed under section 153C rather than section 143(3). Following the precedent established in Jasjit Singh (affirmed by Delhi HC), the ITAT allowed the assessee's appeal and quashed the improperly framed assessment.
The ITAT quashed the assessment order passed under section 143(3) dated 27/03/2015. The Tribunal held that since the satisfaction note for initiating proceedings under section 153C was recorded on 10/10/2024, the assessment year relevant to the search was AY 2015-16, with the preceding six years being AY 2009-10 to 2014-15. As the impugned AY 2013-14 fell within this block period, the assessment should have been completed under section 153C rather than section 143(3). Following the precedent established in Jasjit Singh (affirmed by Delhi HC), the ITAT allowed the assessee's appeal and quashed the improperly framed assessment.
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