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 issued by Jurisdictional Assessing Officers (JAOs), ruling they lacked jurisdiction under Section 151A of the Income Tax Act. The court held that Faceless Assessing Officers (FAOs) have exclusive jurisdiction for notices under Sections 147 and 148, as mandated by the CBDT Notification dated 29.03.2022. The court emphasized that concurrent jurisdiction between JAOs and FAOs would defeat the statutory purpose of Sections 151A and 144B. The algorithmic random allocation system must be strictly followed to maintain the integrity of the faceless assessment regime. Liberty was granted to respondents to issue fresh notices through proper FAO channels in compliance with the notification.
The HC quashed reassessment notices issued by Jurisdictional Assessing Officers (JAOs), ruling they lacked jurisdiction under Section 151A of the Income Tax Act. The court held that Faceless Assessing Officers (FAOs) have exclusive jurisdiction for notices under Sections 147 and 148, as mandated by the CBDT Notification dated 29.03.2022. The court emphasized that concurrent jurisdiction between JAOs and FAOs would defeat the statutory purpose of Sections 151A and 144B. The algorithmic random allocation system must be strictly followed to maintain the integrity of the faceless assessment regime. Liberty was granted to respondents to issue fresh notices through proper FAO channels in compliance with the notification.
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