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 ruled that the reassessment proceedings under Section 143(3) were valid despite time limitations. The AO had legitimate reasons to believe income had escaped assessment due to the petitioner's failure to fully disclose material facts regarding MAT exemption. Specifically, the petitioner claimed deductions from a BIFR scheme without proper CBDT authorization, which constituted non-disclosure. The court found the objection regarding time-barred notice involved complex factual and legal issues inappropriate for writ jurisdiction. Consequently, the writ petition was dismissed, upholding the AO's decision to reopen the assessment based on non-disclosure of essential tax-related information.
HC ruled that the reassessment proceedings under Section 143(3) were valid despite time limitations. The AO had legitimate reasons to believe income had escaped assessment due to the petitioner's failure to fully disclose material facts regarding MAT exemption. Specifically, the petitioner claimed deductions from a BIFR scheme without proper CBDT authorization, which constituted non-disclosure. The court found the objection regarding time-barred notice involved complex factual and legal issues inappropriate for writ jurisdiction. Consequently, the writ petition was dismissed, upholding the AO's decision to reopen the assessment based on non-disclosure of essential tax-related information.
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