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 Petitioner (an anonymized corporate assessee) moved the HC challenging territorial jurisdiction and validity of reopening under s.148 of the IT Act read with the extended limitation provisions under TOLA; the Court held that, following relocation of the Petitioner's registered office to Mumbai and substantial events arising within the HC's territory, a substantial part of the cause of action arose within the HC's jurisdiction under Art.226(2), rejecting the forum conveniens objection. Applying binding precedent, the HC set aside the impugned s.148 notice and all consequential proceedings, thereby quashing the reopening and terminating the assessment action initiated pursuant to that notice.
The Petitioner (an anonymized corporate assessee) moved the HC challenging territorial jurisdiction and validity of reopening under s.148 of the IT Act read with the extended limitation provisions under TOLA; the Court held that, following relocation of the Petitioner's registered office to Mumbai and substantial events arising within the HC's territory, a substantial part of the cause of action arose within the HC's jurisdiction under Art.226(2), rejecting the forum conveniens objection. Applying binding precedent, the HC set aside the impugned s.148 notice and all consequential proceedings, thereby quashing the reopening and terminating the assessment action initiated pursuant to that notice.
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