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 digital notice signed on 31.03.2021 but emailed and dispatched on 01.04.2021 did not vitiate reassessment proceedings under Section 147/149 of the Income Tax Act. The court determined that jurisdictional notice requirements were technically met, and subsequent steps taken by revenue authorities were valid. Despite potential procedural irregularities, the court dismissed the petitioner's challenge, affirming the reassessment proceedings as legally sustainable based on recent Supreme Court precedents regarding notice issuance and jurisdictional requirements.
HC held that the digital notice signed on 31.03.2021 but emailed and dispatched on 01.04.2021 did not vitiate reassessment proceedings under Section 147/149 of the Income Tax Act. The court determined that jurisdictional notice requirements were technically met, and subsequent steps taken by revenue authorities were valid. Despite potential procedural irregularities, the court dismissed the petitioner's challenge, affirming the reassessment proceedings as legally sustainable based on recent Supreme Court precedents regarding notice issuance and jurisdictional requirements.
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