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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ITAT quashed reassessment notice under Section 148 issued on 20/07/2022 for Assessment Year 2017-18, holding it time-barred. Following Supreme Court precedent in UOI vs. Ashish Agarwal, the three-year limitation period expired on 31/03/2021. Although notices issued between 01/04/2021 and 30/06/2021 were deemed issued on 31/03/2021, the extended period for completing Section 148A procedures under new provisions was available only until 30/06/2021. Revenue had merely 20 days to complete entire procedure under Section 149(1) and issue fresh notice under new regime. Since notice was issued beyond limitation period, it was quashed and consequent reassessment order declared void ab initio. Assessee's appeal succeeded on limitation grounds.
ITAT quashed reassessment notice under Section 148 issued on 20/07/2022 for Assessment Year 2017-18, holding it time-barred. Following Supreme Court precedent in UOI vs. Ashish Agarwal, the three-year limitation period expired on 31/03/2021. Although notices issued between 01/04/2021 and 30/06/2021 were deemed issued on 31/03/2021, the extended period for completing Section 148A procedures under new provisions was available only until 30/06/2021. Revenue had merely 20 days to complete entire procedure under Section 149(1) and issue fresh notice under new regime. Since notice was issued beyond limitation period, it was quashed and consequent reassessment order declared void ab initio. Assessee's appeal succeeded on limitation grounds.
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