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 reopening notices issued under section 148 between 01.04.2021 and 30.06.2021, treated as deemed notices under section 148A(b), followed by show-cause notices and orders under section 148A(d), and subsequent reassessment notices issued post-July 2022, were subject to the limitation regime under the amended provisions. Applying the Supreme Court's ruling in Rajeev Bansal, the court found that the impugned reassessment notices were issued beyond the prescribed limitation period. Consequently, all such notices were declared time-barred and quashed. The assessee's appeal was allowed, thereby invalidating the reopening of assessments under section 147 due to non-compliance with the statutory limitation framework as amended and extended during the COVID-19 period.
The HC held that reopening notices issued under section 148 between 01.04.2021 and 30.06.2021, treated as deemed notices under section 148A(b), followed by show-cause notices and orders under section 148A(d), and subsequent reassessment notices issued post-July 2022, were subject to the limitation regime under the amended provisions. Applying the Supreme Court's ruling in Rajeev Bansal, the court found that the impugned reassessment notices were issued beyond the prescribed limitation period. Consequently, all such notices were declared time-barred and quashed. The assessee's appeal was allowed, thereby invalidating the reopening of assessments under section 147 due to non-compliance with the statutory limitation framework as amended and extended during the COVID-19 period.
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