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 held that the issuance of the notice under section 148A(b) of the Act was beyond the prescribed period of limitation under section 149(1)(a), as the AO issued the notice on the last permissible date but failed to extend the order-passing period under section 148A(d) to the mandatory seven days. The AO's initial decision against reopening the assessment was revised solely based on the specified authority's approval, which did not cure the limitation defect. Since the case did not fall under the extended limitation clause, the notice was invalid. Consequently, the reopening of assessment was barred, and the impugned notice was quashed, affirming that adherence to the limitation period and procedural safeguards under sections 148, 148A, and 149 is mandatory for reopening assessments.
The HC held that the issuance of the notice under section 148A(b) of the Act was beyond the prescribed period of limitation under section 149(1)(a), as the AO issued the notice on the last permissible date but failed to extend the order-passing period under section 148A(d) to the mandatory seven days. The AO's initial decision against reopening the assessment was revised solely based on the specified authority's approval, which did not cure the limitation defect. Since the case did not fall under the extended limitation clause, the notice was invalid. Consequently, the reopening of assessment was barred, and the impugned notice was quashed, affirming that adherence to the limitation period and procedural safeguards under sections 148, 148A, and 149 is mandatory for reopening assessments.
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