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 seizure of a 49 gms gold parcel dispatched for job work does not constitute incriminating material for reopening assessments for AYs 2012-13 to 2017-18. The Assessing Officer (AO) failed to record satisfaction that the seized material bore any nexus with the petitioner's income. Following precedents, the court set aside the impugned notices and order under Section 153C, thereby allowing the assessee's appeal and quashing proceedings initiated without valid justification.
HC held that the seizure of a 49 gms gold parcel dispatched for job work does not constitute incriminating material for reopening assessments for AYs 2012-13 to 2017-18. The Assessing Officer (AO) failed to record satisfaction that the seized material bore any nexus with the petitioner's income. Following precedents, the court set aside the impugned notices and order under Section 153C, thereby allowing the assessee's appeal and quashing proceedings initiated without valid justification.
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