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 under Section 245 of the IT Act, once an intimation is received, the assessee must respond; failing which the ITO may lawfully adjust refunds against outstanding tax liabilities without issuing further intimation or affording additional opportunity. The petitioner's failure to act after receiving such intimation justified the set-off of refunds for AY 2024-25 against dues for AY 2018-19. However, regarding refunds for AYs 2021-22, 2022-23, and 2023-24, the court directed the AO to issue an intimation within one week, provide the petitioner a hearing opportunity, and verify if any excess adjustment beyond the prescribed 20% limit under CBDT Office Memoranda occurred during the appeal pendency. If excess set-off is found, the AO must restore the amount to the petitioner. The writ petition was allowed accordingly, with no order as to costs.
The HC held that under Section 245 of the IT Act, once an intimation is received, the assessee must respond; failing which the ITO may lawfully adjust refunds against outstanding tax liabilities without issuing further intimation or affording additional opportunity. The petitioner's failure to act after receiving such intimation justified the set-off of refunds for AY 2024-25 against dues for AY 2018-19. However, regarding refunds for AYs 2021-22, 2022-23, and 2023-24, the court directed the AO to issue an intimation within one week, provide the petitioner a hearing opportunity, and verify if any excess adjustment beyond the prescribed 20% limit under CBDT Office Memoranda occurred during the appeal pendency. If excess set-off is found, the AO must restore the amount to the petitioner. The writ petition was allowed accordingly, with no order as to costs.
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