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 dismissed the assessee's appeal challenging reopening of assessment and additions under section 68. The assessee failed to file income tax return and accounts filed were found unsatisfactory by the Assessing Officer. The assessee did not specifically challenge additions under section 68 and provided no details regarding business turnover, sales, purchases, or expenses before either the Commissioner of Income Tax (Appeals) or ITAT. The tribunal found no fault in the AO's assumption of jurisdiction. Since no return was filed in response to notice under section 148, the AO correctly passed assessment order under section 144. The appeal was dismissed as the primary grounds challenging jurisdictional assumption failed.
ITAT dismissed the assessee's appeal challenging reopening of assessment and additions under section 68. The assessee failed to file income tax return and accounts filed were found unsatisfactory by the Assessing Officer. The assessee did not specifically challenge additions under section 68 and provided no details regarding business turnover, sales, purchases, or expenses before either the Commissioner of Income Tax (Appeals) or ITAT. The tribunal found no fault in the AO's assumption of jurisdiction. Since no return was filed in response to notice under section 148, the AO correctly passed assessment order under section 144. The appeal was dismissed as the primary grounds challenging jurisdictional assumption failed.
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