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 upheld the jurisdiction of the Income Tax Officer (ACIT/DCIT) to issue notice u/s 143(2), rejecting contentions challenging the authority's competence. The court determined that both the Assessing Officer (AO) and prescribed income tax authority can validly issue such notices. The ruling affirmed the broad discretionary powers of tax authorities under the Income Tax Act, specifically emphasizing that the National Faceless Assessment Centre (NaFAC) does not exclusively possess notice-issuing powers. The judgment conclusively established the procedural validity of the tax assessment process and the administrative flexibility of tax officers in conducting assessments.
HC upheld the jurisdiction of the Income Tax Officer (ACIT/DCIT) to issue notice u/s 143(2), rejecting contentions challenging the authority's competence. The court determined that both the Assessing Officer (AO) and prescribed income tax authority can validly issue such notices. The ruling affirmed the broad discretionary powers of tax authorities under the Income Tax Act, specifically emphasizing that the National Faceless Assessment Centre (NaFAC) does not exclusively possess notice-issuing powers. The judgment conclusively established the procedural validity of the tax assessment process and the administrative flexibility of tax officers in conducting assessments.
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