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 u/s 148 issued beyond three-year limitation period. Assessee engaged in derivative trading, booking profits within seconds by purchasing and immediately selling scrips at higher rates. AO alleged non-genuine profits constituted escaped income. Tribunal held mandatory conditions under s.149(1)(b) not satisfied as AO possessed no evidence of assets representing escaped income, no expenditure escaped assessment, and trading entries were already disclosed in books and credited to P&L account. Since profits were utilized for loan repayment and transactions were properly recorded, no income escaped assessment. Notice being time-barred and lacking statutory compliance was quashed. Assessee's appeal allowed.
ITAT quashed reassessment notice u/s 148 issued beyond three-year limitation period. Assessee engaged in derivative trading, booking profits within seconds by purchasing and immediately selling scrips at higher rates. AO alleged non-genuine profits constituted escaped income. Tribunal held mandatory conditions under s.149(1)(b) not satisfied as AO possessed no evidence of assets representing escaped income, no expenditure escaped assessment, and trading entries were already disclosed in books and credited to P&L account. Since profits were utilized for loan repayment and transactions were properly recorded, no income escaped assessment. Notice being time-barred and lacking statutory compliance was quashed. Assessee's appeal allowed.
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