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 dismissed the writ appeal challenging reassessment proceedings under Section 147. The AO reopened the assessment based on a District Valuation Officer's report revealing discrepancies in construction expenditure and undisclosed income. The court found the reassessment valid, noting the Assessing Officer recorded legitimate reasons for believing income had escaped assessment. The appellant was afforded opportunity to raise defenses through appellate proceedings. Considering the fresh order passed by the Assessing Authority and alternative remedy under Section 246A, the intra-court appeal was rejected without interference, effectively decided against the assessee.
HC dismissed the writ appeal challenging reassessment proceedings under Section 147. The AO reopened the assessment based on a District Valuation Officer's report revealing discrepancies in construction expenditure and undisclosed income. The court found the reassessment valid, noting the Assessing Officer recorded legitimate reasons for believing income had escaped assessment. The appellant was afforded opportunity to raise defenses through appellate proceedings. Considering the fresh order passed by the Assessing Authority and alternative remedy under Section 246A, the intra-court appeal was rejected without interference, effectively decided against the assessee.
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