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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HC held that the second Section 148 notice was issued beyond the statutory limitation period of four years from the end of AY 2016-17. The first Section 148 notice was validly issued on 23.06.2021, six days before the extended limitation deadline. However, the subsequent second Section 148 notice was time-barred. Consequently, all proceedings initiated pursuant to the second notice were set aside. The court relied on precedential rulings and statutory interpretations, specifically focusing on procedural time constraints in tax reassessment proceedings. The decision effectively invalidated the subsequent reassessment notice due to non-compliance with prescribed limitation periods.
HC held that the second Section 148 notice was issued beyond the statutory limitation period of four years from the end of AY 2016-17. The first Section 148 notice was validly issued on 23.06.2021, six days before the extended limitation deadline. However, the subsequent second Section 148 notice was time-barred. Consequently, all proceedings initiated pursuant to the second notice were set aside. The court relied on precedential rulings and statutory interpretations, specifically focusing on procedural time constraints in tax reassessment proceedings. The decision effectively invalidated the subsequent reassessment notice due to non-compliance with prescribed limitation periods.
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