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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The HC dismissed the petition challenging reopening under s.147/148, holding the reopening valid because the scheme of merger became effective only upon NCLT sanction on 13.11.2020; until then the petitioner remained a distinct legal entity with an active PAN and conducted financial transactions in AY 2020-21. The CBDT Risk Management Strategy report identified transactions totaling Rs. 11,64,12,993 which, under explanation 1 to s.148, escaped assessment. The Court found the transferee's return was accepted as nil after scrutiny, but the petitioner continued business during the merger process; consequently the petitioner's contention of cessation from 01.04.2018 was rejected and the writ petition was dismissed.
The HC dismissed the petition challenging reopening under s.147/148, holding the reopening valid because the scheme of merger became effective only upon NCLT sanction on 13.11.2020; until then the petitioner remained a distinct legal entity with an active PAN and conducted financial transactions in AY 2020-21. The CBDT Risk Management Strategy report identified transactions totaling Rs. 11,64,12,993 which, under explanation 1 to s.148, escaped assessment. The Court found the transferee's return was accepted as nil after scrutiny, but the petitioner continued business during the merger process; consequently the petitioner's contention of cessation from 01.04.2018 was rejected and the writ petition was dismissed.
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