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 notice issued under Section 148 for AY 2017-18 on 1st May 2024 is barred by limitation as per the first proviso to Section 149(1) of the Act, since the six-year period expired on 31st March 2024. The court rejected the argument that the fifth and sixth provisos to Section 149(1)(b) could extend this limitation period once the first proviso's restriction is breached. Furthermore, the impugned notice issued by the Jurisdictional Assessing Officer (JAO) instead of the Faceless Assessing Officer (FAO) was declared invalid and bad in law for non-compliance with Section 151A. The decision aligns with precedents from the Bombay HC and has been followed by other High Courts, reinforcing that notices under Section 148 must be issued by FAO to be valid. Consequently, the notice in question was quashed.
The HC held that the notice issued under Section 148 for AY 2017-18 on 1st May 2024 is barred by limitation as per the first proviso to Section 149(1) of the Act, since the six-year period expired on 31st March 2024. The court rejected the argument that the fifth and sixth provisos to Section 149(1)(b) could extend this limitation period once the first proviso's restriction is breached. Furthermore, the impugned notice issued by the Jurisdictional Assessing Officer (JAO) instead of the Faceless Assessing Officer (FAO) was declared invalid and bad in law for non-compliance with Section 151A. The decision aligns with precedents from the Bombay HC and has been followed by other High Courts, reinforcing that notices under Section 148 must be issued by FAO to be valid. Consequently, the notice in question was quashed.
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