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 an unsigned assessment order is a nullity and cannot be subsequently validated by signing after service on the assessee. The assessment order dated 22.01.2025 for AY 2022-23 was found to be unsigned both on record and on the ITBA portal. The Tribunal rejected the Revenue's contention that the defect was curable, emphasizing that non-signature renders the order incomplete and invalid. Reliance was placed on precedent where a coordinate bench quashed a similarly unsigned assessment order. Consequently, the ITAT quashed the impugned unsigned assessment order, affirming that such an order lacks legal validity and cannot be treated as a valid assessment.
The ITAT held that an unsigned assessment order is a nullity and cannot be subsequently validated by signing after service on the assessee. The assessment order dated 22.01.2025 for AY 2022-23 was found to be unsigned both on record and on the ITBA portal. The Tribunal rejected the Revenue's contention that the defect was curable, emphasizing that non-signature renders the order incomplete and invalid. Reliance was placed on precedent where a coordinate bench quashed a similarly unsigned assessment order. Consequently, the ITAT quashed the impugned unsigned assessment order, affirming that such an order lacks legal validity and cannot be treated as a valid assessment.
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