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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ITAT set aside reassessment notice u/s 148 dated 28/07/2022 as time-barred. Applying the SC jurisprudence on interplay between pre- and post-TOLA regimes, the Tribunal held that only the balance or "surviving" period available under the Income-tax Act read with TOLA may be used to complete post-deemed-notice steps, including issuance of a fresh s.148 notice. The original notice dated 30/06/2021 operated as a deemed notice; the surviving window ran only from 28/06/2021 to 30/06/2021 (two days). The AO failed to complete s.148A(c)/(d) and issue s.148 within that surviving period after expiry of the assessee's reply deadline, rendering the impugned notice barred by limitation and quashed.
ITAT set aside reassessment notice u/s 148 dated 28/07/2022 as time-barred. Applying the SC jurisprudence on interplay between pre- and post-TOLA regimes, the Tribunal held that only the balance or "surviving" period available under the Income-tax Act read with TOLA may be used to complete post-deemed-notice steps, including issuance of a fresh s.148 notice. The original notice dated 30/06/2021 operated as a deemed notice; the surviving window ran only from 28/06/2021 to 30/06/2021 (two days). The AO failed to complete s.148A(c)/(d) and issue s.148 within that surviving period after expiry of the assessee's reply deadline, rendering the impugned notice barred by limitation and quashed.
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