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 quashed a Section 148 notice for reassessment as it was issued beyond the statutory six-year limitation period. The revenue contended the notice dated 31.3.2021 was validly issued within time, but the departmental screenshot showed the email was sent on 01.04.2021 at 03:58:33 AM with delivery occurring within three microseconds. Despite the assessing officer's signature timestamp of 31.3.2021 at 18:36 PM, the court held that the actual system dispatch time was determinative. The revenue failed to provide evidence that the notice was placed in the system on 31.3.2021, and their plea regarding traffic congestion was rejected due to lack of supporting material. The petition was allowed, and the reassessment notice was quashed for being time-barred.
The HC quashed a Section 148 notice for reassessment as it was issued beyond the statutory six-year limitation period. The revenue contended the notice dated 31.3.2021 was validly issued within time, but the departmental screenshot showed the email was sent on 01.04.2021 at 03:58:33 AM with delivery occurring within three microseconds. Despite the assessing officer's signature timestamp of 31.3.2021 at 18:36 PM, the court held that the actual system dispatch time was determinative. The revenue failed to provide evidence that the notice was placed in the system on 31.3.2021, and their plea regarding traffic congestion was rejected due to lack of supporting material. The petition was allowed, and the reassessment notice was quashed for being time-barred.
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