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 held that for assessments under Section 153C involving non-searched persons, the limitation period for block assessment years must be calculated from the date of handing over incriminating material and recording satisfaction, not from the actual search date. Since notices under Section 153C were issued on 26.09.2019, making 2020-21 the search year for the assessee as "other person," assessments for AYs 2014-15 to 2019-20 fell within permissible block assessment periods. The Tribunal distinguished Section 153C assessments from Section 153A, establishing that the relevant date for determining the six-year block period is when seized materials are transferred to the jurisdictional assessing officer rather than the original search date. Decision favored revenue.
ITAT held that for assessments under Section 153C involving non-searched persons, the limitation period for block assessment years must be calculated from the date of handing over incriminating material and recording satisfaction, not from the actual search date. Since notices under Section 153C were issued on 26.09.2019, making 2020-21 the search year for the assessee as "other person," assessments for AYs 2014-15 to 2019-20 fell within permissible block assessment periods. The Tribunal distinguished Section 153C assessments from Section 153A, establishing that the relevant date for determining the six-year block period is when seized materials are transferred to the jurisdictional assessing officer rather than the original search date. Decision favored revenue.
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