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 upheld the validity of the reopening of assessment under Section 147, holding that the notice issued under Section 148 was not barred by limitation. The Court clarified that, pursuant to Section 149's scheme, the period during which the assessee was given extended time via the show-cause notice under Section 148A(b), as well as any stay of proceedings under Section 148, must be excluded from the limitation period. Consequently, the notice issued on 25.09.2024, though beyond three years from the end of the AY 2020-21, was within the extended limitation period after excluding the interval from 01.04.2021 to 20.03.2022. The sanction granted by the Principal Commissioner under Section 151(i) was held lawful. Reliance on extant precedents affirmed that limitation provisions apply equally to the Department, thereby validating the reopening and dismissing the assessee's challenge.
The HC upheld the validity of the reopening of assessment under Section 147, holding that the notice issued under Section 148 was not barred by limitation. The Court clarified that, pursuant to Section 149's scheme, the period during which the assessee was given extended time via the show-cause notice under Section 148A(b), as well as any stay of proceedings under Section 148, must be excluded from the limitation period. Consequently, the notice issued on 25.09.2024, though beyond three years from the end of the AY 2020-21, was within the extended limitation period after excluding the interval from 01.04.2021 to 20.03.2022. The sanction granted by the Principal Commissioner under Section 151(i) was held lawful. Reliance on extant precedents affirmed that limitation provisions apply equally to the Department, thereby validating the reopening and dismissing the assessee's challenge.
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