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 held that the reassessment proceedings were invalid due to improper service of notice u/s 148. The AO failed to demonstrate valid notice service to the assessee, serving instead on a tax consultant without establishing authorized representation. The tribunal found no evidence confirming the notice was served at the correct address. Consequently, the entire reassessment proceedings were quashed as the fundamental procedural requirement of proper notice was not fulfilled, rendering the subsequent assessment proceedings legally unsustainable.
ITAT held that the reassessment proceedings were invalid due to improper service of notice u/s 148. The AO failed to demonstrate valid notice service to the assessee, serving instead on a tax consultant without establishing authorized representation. The tribunal found no evidence confirming the notice was served at the correct address. Consequently, the entire reassessment proceedings were quashed as the fundamental procedural requirement of proper notice was not fulfilled, rendering the subsequent assessment proceedings legally unsustainable.
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