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 Form 26AS with apparent errors cannot constitute tangible material for reopening assessment. The assessment order was invalid as duplicate entries in Form 26AS showed only a minimal discrepancy of Rs. 1,926/- in salary income. The revenue's argument regarding extended limitation period was rejected. The AO lacked sufficient grounds to believe income had escaped assessment. Appellate authorities CIT(A) and ITAT concurred that the reassessment was unsustainable. The court ultimately decided in favor of the assessee, nullifying the reassessment proceedings due to lack of substantive evidence of income escapement.
HC held that Form 26AS with apparent errors cannot constitute tangible material for reopening assessment. The assessment order was invalid as duplicate entries in Form 26AS showed only a minimal discrepancy of Rs. 1,926/- in salary income. The revenue's argument regarding extended limitation period was rejected. The AO lacked sufficient grounds to believe income had escaped assessment. Appellate authorities CIT(A) and ITAT concurred that the reassessment was unsustainable. The court ultimately decided in favor of the assessee, nullifying the reassessment proceedings due to lack of substantive evidence of income escapement.
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