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 invalidated the assessment proceedings due to procedural irregularity in issuing show cause notice. The notice was served with insufficient response time, specifically less than the mandated 7-day period under Section 144 read with Section 144B. The court set aside the impugned assessment order and related notices, directing the respondent to recommence proceedings from the show cause notice stage, ensuring strict compliance with statutory timelines and principles of natural justice.
HC invalidated the assessment proceedings due to procedural irregularity in issuing show cause notice. The notice was served with insufficient response time, specifically less than the mandated 7-day period under Section 144 read with Section 144B. The court set aside the impugned assessment order and related notices, directing the respondent to recommence proceedings from the show cause notice stage, ensuring strict compliance with statutory timelines and principles of natural justice.
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