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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The HC invalidated reassessment proceedings under Sections 148A and 148, finding them procedurally non-compliant with the Finance Act, 2021. Following its prior ruling in a similar case, the court quashed the impugned notices issued by the jurisdictional Assessing Officer. The decision was rendered subject to the Supreme Court's outcome in the pending Special Leave Petition challenging the earlier precedent. The writ petition was allowed in favor of the assessee, setting aside the notices on jurisdictional grounds, with liberty to either party to seek revival based on the Supreme Court's eventual ruling.
The HC invalidated reassessment proceedings under Sections 148A and 148, finding them procedurally non-compliant with the Finance Act, 2021. Following its prior ruling in a similar case, the court quashed the impugned notices issued by the jurisdictional Assessing Officer. The decision was rendered subject to the Supreme Court's outcome in the pending Special Leave Petition challenging the earlier precedent. The writ petition was allowed in favor of the assessee, setting aside the notices on jurisdictional grounds, with liberty to either party to seek revival based on the Supreme Court's eventual ruling.
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