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 assessment order passed against the non-existent partnership firm, which had been converted into an LLP prior to the assessment year, was void ab initio. The AO's rejection of the conversion was solely based on the non-communication to the department and absence of KYC documents, disregarding the assessee's submissions and evidence demonstrating full disclosure of transactions in the LLP's books and the filing of the relevant Return of Income. Consequently, the assessment order against the erstwhile partnership firm lacked legal validity and was quashed.
The HC held that the assessment order passed against the non-existent partnership firm, which had been converted into an LLP prior to the assessment year, was void ab initio. The AO's rejection of the conversion was solely based on the non-communication to the department and absence of KYC documents, disregarding the assessee's submissions and evidence demonstrating full disclosure of transactions in the LLP's books and the filing of the relevant Return of Income. Consequently, the assessment order against the erstwhile partnership firm lacked legal validity and was quashed.
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