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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC determined that the assessment order and demand notice were invalid due to procedural irregularities. The court found that the petitioner was given insufficient time to respond to the show-cause notice, and the assessing authority failed to consider the reply submitted on 27th March, 2022. Consequently, the HC quashed the existing assessment order and demand notice, remanding the matter back to the Assessing Officer to conduct a fresh de novo review, ensuring proper consideration of the petitioner's submissions and adherence to procedural fairness.
HC determined that the assessment order and demand notice were invalid due to procedural irregularities. The court found that the petitioner was given insufficient time to respond to the show-cause notice, and the assessing authority failed to consider the reply submitted on 27th March, 2022. Consequently, the HC quashed the existing assessment order and demand notice, remanding the matter back to the Assessing Officer to conduct a fresh de novo review, ensuring proper consideration of the petitioner's submissions and adherence to procedural fairness.
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