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 ITAT held that the reassessment initiated under s.148 was invalid because the assessee complied with all notices and there was no suppression of material facts warranting reopening; consequently the reassessment proceedings are non est. Having found the reassessment void ab initio, the revisionary order passed by the AO under s.263 lacks jurisdiction and is set aside. The appeal by the assessee is allowed, with directions that no addition on account of alleged bogus expenditure or interest under s.234A for the specified period shall be sustained pursuant to the impugned proceedings. The AO is precluded from pursuing the contested reassessment and revision further.
The ITAT held that the reassessment initiated under s.148 was invalid because the assessee complied with all notices and there was no suppression of material facts warranting reopening; consequently the reassessment proceedings are non est. Having found the reassessment void ab initio, the revisionary order passed by the AO under s.263 lacks jurisdiction and is set aside. The appeal by the assessee is allowed, with directions that no addition on account of alleged bogus expenditure or interest under s.234A for the specified period shall be sustained pursuant to the impugned proceedings. The AO is precluded from pursuing the contested reassessment and revision further.
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