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 held that the Block Assessment Order dated 28.03.2002 under Section 158BC of the Income Tax Act was valid and within prescribed limitation. The search spanning multiple dates (08.12.1999, 21.01.2000, and 02.03.2000) with partial document seizure did not invalidate the assessment. The Prohibitory Order under Section 132(3) was not considered a "deemed seizure", and the assessment was completed within the statutory timeframe. Given the block period covering 1990-1991 to 1999-2000, the Appellate Tribunal was directed to expedite the pending appeal considering the substantial time already elapsed in litigation.
HC held that the Block Assessment Order dated 28.03.2002 under Section 158BC of the Income Tax Act was valid and within prescribed limitation. The search spanning multiple dates (08.12.1999, 21.01.2000, and 02.03.2000) with partial document seizure did not invalidate the assessment. The Prohibitory Order under Section 132(3) was not considered a "deemed seizure", and the assessment was completed within the statutory timeframe. Given the block period covering 1990-1991 to 1999-2000, the Appellate Tribunal was directed to expedite the pending appeal considering the substantial time already elapsed in litigation.
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