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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT allowed the assessee's appeal, invalidating the reassessment proceedings due to procedural defects. The Pr. CIT's approval for reopening assessment under Section 148 was deemed invalid, as the use of "may be reopened" indicated a casual approach without proper application of mind. The tribunal found no independent satisfaction by the competent authority, and the approval failed to meet the statutory requirements of Section 151. The notice was issued prematurely, without adhering to legal provisions, rendering the reassessment proceedings technically unsustainable. Consequently, the reopening of assessment was quashed on procedural grounds.
ITAT allowed the assessee's appeal, invalidating the reassessment proceedings due to procedural defects. The Pr. CIT's approval for reopening assessment under Section 148 was deemed invalid, as the use of "may be reopened" indicated a casual approach without proper application of mind. The tribunal found no independent satisfaction by the competent authority, and the approval failed to meet the statutory requirements of Section 151. The notice was issued prematurely, without adhering to legal provisions, rendering the reassessment proceedings technically unsustainable. Consequently, the reopening of assessment was quashed on procedural grounds.
Note: It is a system-generated summary and is for quick reference only.