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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ITAT adjudicated a tax reassessment case involving procedural irregularities in notice service. The tribunal found that the Revenue department failed to substantiate proper service of Section 148 notice to the assessee. The Assessing Officer explicitly acknowledged that the issued notice was returned unserved. Consequently, the tribunal determined that no valid notice was effectively served to the taxpayer. Based on this critical procedural defect, the reassessment proceedings under Section 144 read with Section 148 were summarily quashed, rendering the entire reassessment process invalid. The final ruling was decisively in favor of the assessee, invalidating the tax department's attempt to reopen the assessment.
ITAT adjudicated a tax reassessment case involving procedural irregularities in notice service. The tribunal found that the Revenue department failed to substantiate proper service of Section 148 notice to the assessee. The Assessing Officer explicitly acknowledged that the issued notice was returned unserved. Consequently, the tribunal determined that no valid notice was effectively served to the taxpayer. Based on this critical procedural defect, the reassessment proceedings under Section 144 read with Section 148 were summarily quashed, rendering the entire reassessment process invalid. The final ruling was decisively in favor of the assessee, invalidating the tax department's attempt to reopen the assessment.
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