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 ITAT held that the search concluded on 26.03.2021, and the restraint order passed under section 132(3) was invalid as it failed to specify reasons justifying non-seizure, rendering the subsequent Panchnama dated 24.05.2021 ineffective to extend the limitation period. The tribunal found no new material seized during the visit on 24.05.2021, which was merely an inspection, not a search. Consequently, the limitation period for assessment crystallized upon the conclusion of the search on 26.03.2021. Since the assessment year 2021-22 was not involved, clause (xi) of section 153B was inapplicable. The impugned assessment orders, therefore, were barred by limitation under section 153B. The ITAT allowed the assessee's contention and quashed the assessment orders as time-barred.
The ITAT held that the search concluded on 26.03.2021, and the restraint order passed under section 132(3) was invalid as it failed to specify reasons justifying non-seizure, rendering the subsequent Panchnama dated 24.05.2021 ineffective to extend the limitation period. The tribunal found no new material seized during the visit on 24.05.2021, which was merely an inspection, not a search. Consequently, the limitation period for assessment crystallized upon the conclusion of the search on 26.03.2021. Since the assessment year 2021-22 was not involved, clause (xi) of section 153B was inapplicable. The impugned assessment orders, therefore, were barred by limitation under section 153B. The ITAT allowed the assessee's contention and quashed the assessment orders as time-barred.
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