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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HC dismissed the petition and upheld the reopening of assessment. The court held that s.149(1)(b) is a jurisdictional fact to be established before reopening for escaped income, and the impugned order rested on a reasonable belief formed after a s.133A survey. The petitioner may adduce ledger entries and material in the pending inquiry; disputed questions of fact (including whether Rs.1,50,50,000 related to advances or AY 2020-21 expenditure) preclude relief under extraordinary writ jurisdiction. The HC found pre-conditions under s.148A(b) satisfied and no jurisdictional error in the exercise under s.148A(d). Article 226 cannot correct intra-jurisdictional errors of law/fact; petition dismissed.
HC dismissed the petition and upheld the reopening of assessment. The court held that s.149(1)(b) is a jurisdictional fact to be established before reopening for escaped income, and the impugned order rested on a reasonable belief formed after a s.133A survey. The petitioner may adduce ledger entries and material in the pending inquiry; disputed questions of fact (including whether Rs.1,50,50,000 related to advances or AY 2020-21 expenditure) preclude relief under extraordinary writ jurisdiction. The HC found pre-conditions under s.148A(b) satisfied and no jurisdictional error in the exercise under s.148A(d). Article 226 cannot correct intra-jurisdictional errors of law/fact; petition dismissed.
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