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 dismissed a writ petition challenging an assessment order under s.143(3) read with s.144B of the Income Tax Act, 1961. The petitioner claimed violation of natural justice due to non-consideration of their application under s.144A. The Court held that with the incorporation of s.144B, which provides adequate procedural safeguards for faceless assessment, the role of the Jurisdictional Joint Commissioner under s.144A has become redundant for s.144B assessments. Section 144A applies only where assessment continues with the Jurisdictional Assessing Officer. The Court granted liberty to file a statutory appeal before the Appellate Commissioner within 30 days.
The HC dismissed a writ petition challenging an assessment order under s.143(3) read with s.144B of the Income Tax Act, 1961. The petitioner claimed violation of natural justice due to non-consideration of their application under s.144A. The Court held that with the incorporation of s.144B, which provides adequate procedural safeguards for faceless assessment, the role of the Jurisdictional Joint Commissioner under s.144A has become redundant for s.144B assessments. Section 144A applies only where assessment continues with the Jurisdictional Assessing Officer. The Court granted liberty to file a statutory appeal before the Appellate Commissioner within 30 days.
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