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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ITAT allowed the appeal, holding the reassessment notice invalid because it was issued after the three-year limitation period without sanction by the authority specified in section 151(ii). The prior approval recorded from the Principal Commissioner was inadequate where the notice was issued beyond three years from the end of the relevant AY; sanction in such cases must come from the Principal Chief Commissioner or Principal Director General, or, if those posts do not exist, from the Chief Commissioner or Director General. Consequently, the reopening lacked lawful authority and any consequential proceedings were quashed, with the taxpayer's challenge to the validity of the assessment sustained.
ITAT allowed the appeal, holding the reassessment notice invalid because it was issued after the three-year limitation period without sanction by the authority specified in section 151(ii). The prior approval recorded from the Principal Commissioner was inadequate where the notice was issued beyond three years from the end of the relevant AY; sanction in such cases must come from the Principal Chief Commissioner or Principal Director General, or, if those posts do not exist, from the Chief Commissioner or Director General. Consequently, the reopening lacked lawful authority and any consequential proceedings were quashed, with the taxpayer's challenge to the validity of the assessment sustained.
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