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 set aside the assessment framed u/s 153C due to the AO's failure to record a valid satisfaction note specifying escaped income for each assessment year, thereby invalidating jurisdiction. The AO's assumption of jurisdiction over A.Y. 2015-16 to 2021-22 was quashed as the satisfaction note was cryptic and did not demonstrate application of mind. The extended limitation period under section 153A was held inapplicable as the alleged escaped income was below Rs. 50 lakhs. The assessment related to A.Y. 2023-24 only, computed from the date incriminating material was received. The addition for alleged on-money payments was deleted for lack of evidence and denial of cross-examination. Enhancement under section 69 was also deleted as the source of funds was satisfactorily explained through sale proceeds and Capital Gains Account Scheme. Grounds challenging jurisdiction, addition, and enhancement were accordingly allowed.
The ITAT set aside the assessment framed u/s 153C due to the AO's failure to record a valid satisfaction note specifying escaped income for each assessment year, thereby invalidating jurisdiction. The AO's assumption of jurisdiction over A.Y. 2015-16 to 2021-22 was quashed as the satisfaction note was cryptic and did not demonstrate application of mind. The extended limitation period under section 153A was held inapplicable as the alleged escaped income was below Rs. 50 lakhs. The assessment related to A.Y. 2023-24 only, computed from the date incriminating material was received. The addition for alleged on-money payments was deleted for lack of evidence and denial of cross-examination. Enhancement under section 69 was also deleted as the source of funds was satisfactorily explained through sale proceeds and Capital Gains Account Scheme. Grounds challenging jurisdiction, addition, and enhancement were accordingly allowed.
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