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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The HC held that the reopening and reassessment were void for jurisdictional error. The petitioner, having executed a unilateral APA and filed the ACR timely, was immune from unilateral examination or adjustment by the JAO in absence of an adverse TPO/CBDT compliance report; only the TPO/DGIT (International Transaction) may audit compliance and initiate cancellation procedures. The JAO also lacked jurisdiction to refuse acceptance of the modified return under s.92CD(1). Further, prior sanction for reopening under s.151 was invalidly obtained from an improper authority for a reopening beyond three years, rendering the issuance of notices under ss.148/148A and the assessment order of 16.01.2024 null and void.
The HC held that the reopening and reassessment were void for jurisdictional error. The petitioner, having executed a unilateral APA and filed the ACR timely, was immune from unilateral examination or adjustment by the JAO in absence of an adverse TPO/CBDT compliance report; only the TPO/DGIT (International Transaction) may audit compliance and initiate cancellation procedures. The JAO also lacked jurisdiction to refuse acceptance of the modified return under s.92CD(1). Further, prior sanction for reopening under s.151 was invalidly obtained from an improper authority for a reopening beyond three years, rendering the issuance of notices under ss.148/148A and the assessment order of 16.01.2024 null and void.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
