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 HC set aside proceedings initiated under sections 148A and 148, holding the notices invalid because they were not issued through the statutorily mandated faceless mechanism introduced by the Finance Act, 2021 and Notification dated 29.03.2022 read with section 151A; the issuance by the territorial AO rendered the reassessment jurisdictionally infirm. Writ petitions by the assessee were allowed, the reassessment proceedings quashed, and consequential reliefs granted. The court noted its prior ruling on the same legal question and observed that subsequent benches in several HCs have reached the same conclusion, uniformly deciding against the revenue on the faceless-notice compliance issue.
The HC set aside proceedings initiated under sections 148A and 148, holding the notices invalid because they were not issued through the statutorily mandated faceless mechanism introduced by the Finance Act, 2021 and Notification dated 29.03.2022 read with section 151A; the issuance by the territorial AO rendered the reassessment jurisdictionally infirm. Writ petitions by the assessee were allowed, the reassessment proceedings quashed, and consequential reliefs granted. The court noted its prior ruling on the same legal question and observed that subsequent benches in several HCs have reached the same conclusion, uniformly deciding against the revenue on the faceless-notice compliance issue.
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