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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT adjudicated a tax assessment reopening case, determining the Income Tax Officer's (ITO) jurisdiction to issue notice under Section 148. The tribunal found that since the value of income escaping assessment was below Rs. 50 lakhs, the ITO lacked legal authority to issue the notice as per Section 149(1)(b). Consistent with precedents from Bombay HC and Madhya Pradesh HC, the tribunal quashed the Section 148A(d) order and consequential assessment order, ruling the notice was procedurally invalid and without jurisdictional merit.
ITAT adjudicated a tax assessment reopening case, determining the Income Tax Officer's (ITO) jurisdiction to issue notice under Section 148. The tribunal found that since the value of income escaping assessment was below Rs. 50 lakhs, the ITO lacked legal authority to issue the notice as per Section 149(1)(b). Consistent with precedents from Bombay HC and Madhya Pradesh HC, the tribunal quashed the Section 148A(d) order and consequential assessment order, ruling the notice was procedurally invalid and without jurisdictional merit.
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