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 quashed and set aside the reopening order and notice. The court held that the AO erred in assuming jurisdiction under s.147 because credits in the account of a cooperative bank during the demonetisation window related to AY 2017-18, not AY 2018-19, and thus could not form the basis for reopening for the impugned year. The AO's reliance solely on transactions with an unnamed trader and the petitioner's alleged failure to produce books was inadequate to establish a prima facie escapement of income. The petitioner had already furnished ledger extracts and the tax audit report in response to the s.148A(b) notice. Consequently, the order under s.148A(d) and the s.148 notice were invalid and set aside.
HC quashed and set aside the reopening order and notice. The court held that the AO erred in assuming jurisdiction under s.147 because credits in the account of a cooperative bank during the demonetisation window related to AY 2017-18, not AY 2018-19, and thus could not form the basis for reopening for the impugned year. The AO's reliance solely on transactions with an unnamed trader and the petitioner's alleged failure to produce books was inadequate to establish a prima facie escapement of income. The petitioner had already furnished ledger extracts and the tax audit report in response to the s.148A(b) notice. Consequently, the order under s.148A(d) and the s.148 notice were invalid and set aside.
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