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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
HC quashed reopening notices under Section 147 for assessment years 2013-14 and 2014-15, holding that AO failed to establish non-disclosure of material facts by petitioner. For AY 2013-14, petitioner had fully disclosed dividend income from BPCL Trust in return, annual report, and Section 14A response. AO's subsequent view that trust distributions don't qualify for Section 10(34) exemption constituted impermissible "change of opinion" rather than income escaping assessment. For AY 2014-15, AO's challenge to Section 32AC deduction was similarly based on already-disclosed facts, representing change of opinion. Court emphasized that mere disagreement with earlier assessment cannot justify reopening after four years when scrutiny assessment under Section 143(3) already conducted and assessee disclosed all material facts. Notices set aside as legally unsustainable.
HC quashed reopening notices under Section 147 for assessment years 2013-14 and 2014-15, holding that AO failed to establish non-disclosure of material facts by petitioner. For AY 2013-14, petitioner had fully disclosed dividend income from BPCL Trust in return, annual report, and Section 14A response. AO's subsequent view that trust distributions don't qualify for Section 10(34) exemption constituted impermissible "change of opinion" rather than income escaping assessment. For AY 2014-15, AO's challenge to Section 32AC deduction was similarly based on already-disclosed facts, representing change of opinion. Court emphasized that mere disagreement with earlier assessment cannot justify reopening after four years when scrutiny assessment under Section 143(3) already conducted and assessee disclosed all material facts. Notices set aside as legally unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
