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 upheld the reassessment proceedings against the taxpayer, finding the AO's reopening of the assessment valid. The court determined that the statutory provisions do not mandate the AO to explicitly point out the assessee's default at the notice stage. The procedural requirements were followed, including furnishing reasons upon request and allowing objections. The court rejected challenges to the reassessment, emphasizing that the procedural steps were consistent with established judicial precedents. The impugned orders were sustained, with the court noting the lower court's non-speaking order was vulnerable but ultimately maintaining the reassessment notices.
HC upheld the reassessment proceedings against the taxpayer, finding the AO's reopening of the assessment valid. The court determined that the statutory provisions do not mandate the AO to explicitly point out the assessee's default at the notice stage. The procedural requirements were followed, including furnishing reasons upon request and allowing objections. The court rejected challenges to the reassessment, emphasizing that the procedural steps were consistent with established judicial precedents. The impugned orders were sustained, with the court noting the lower court's non-speaking order was vulnerable but ultimately maintaining the reassessment notices.
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