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 dismissed the petition and upheld searches and seizures conducted under s.132 of the Act, holding the satisfaction note and approval by the DGIT established bona fide "reasons to believe" that income chargeable to tax had escaped assessment and that the petitioners would possess valuables disproportionate to known income. The Court held the three clauses of s.132(1) are disjunctive, so prior service of summons was not a prerequisite, and that formation of opinion under s.132 is an administrative act subject to limited judicial review confined to mala fides or absence of any real reasons. No persuasive evidence of malice or collateral purpose was shown, so interference was refused and the petition dismissed.
The HC dismissed the petition and upheld searches and seizures conducted under s.132 of the Act, holding the satisfaction note and approval by the DGIT established bona fide "reasons to believe" that income chargeable to tax had escaped assessment and that the petitioners would possess valuables disproportionate to known income. The Court held the three clauses of s.132(1) are disjunctive, so prior service of summons was not a prerequisite, and that formation of opinion under s.132 is an administrative act subject to limited judicial review confined to mala fides or absence of any real reasons. No persuasive evidence of malice or collateral purpose was shown, so interference was refused and the petition dismissed.
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