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 beyond three years from relevant Assessment Year due to invalid prior approval. The Assessing Officer obtained approval from Principal Commissioner instead of specified authority as mandated under section 151(ii), which requires approval from Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General for notices beyond three-year period. Consequently, the entire reopening proceedings and reassessment order were declared invalid. Additionally, ITAT deleted addition under section 56(2)(viia) as the difference between actual consideration and stamp duty valuation was only 8.27%, falling below the 10% threshold for applicability of deemed income provisions. The assessee's appeal was allowed on both legal and merit grounds, with all additions quashed.
ITAT quashed reassessment notice under section 148 issued beyond three years from relevant Assessment Year due to invalid prior approval. The Assessing Officer obtained approval from Principal Commissioner instead of specified authority as mandated under section 151(ii), which requires approval from Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General for notices beyond three-year period. Consequently, the entire reopening proceedings and reassessment order were declared invalid. Additionally, ITAT deleted addition under section 56(2)(viia) as the difference between actual consideration and stamp duty valuation was only 8.27%, falling below the 10% threshold for applicability of deemed income provisions. The assessee's appeal was allowed on both legal and merit grounds, with all additions quashed.
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