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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT dismissed revenue's appeal in reassessment proceedings u/s 147. Despite AO treating assessee's return as non-est due to lack of e-verification, AO computed assessed income from returned income, indicating cognizance of the return. Assessee rectified e-verification defect immediately upon notification. AO failed to issue mandatory notice u/s 143(2) and furnish reasons for reopening assessment, constituting jurisdictional defects not curable u/s 292BB. ITAT held these procedural failures fatal to reassessment proceedings, relying on Hotel Blue Moon and CIT vs Trend Electronics precedents establishing that absence of s.143(2) notice invalidates assumption of jurisdiction and non-furnishing of reopening reasons renders reassessment proceedings void. Reassessment proceedings quashed.
ITAT dismissed revenue's appeal in reassessment proceedings u/s 147. Despite AO treating assessee's return as non-est due to lack of e-verification, AO computed assessed income from returned income, indicating cognizance of the return. Assessee rectified e-verification defect immediately upon notification. AO failed to issue mandatory notice u/s 143(2) and furnish reasons for reopening assessment, constituting jurisdictional defects not curable u/s 292BB. ITAT held these procedural failures fatal to reassessment proceedings, relying on Hotel Blue Moon and CIT vs Trend Electronics precedents establishing that absence of s.143(2) notice invalidates assumption of jurisdiction and non-furnishing of reopening reasons renders reassessment proceedings void. Reassessment proceedings quashed.
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