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 quashed the reassessment orders for AYs 2013-14 and 2014-15, finding jurisdictional defects: the assessing authorities failed to supply the sanction under section 151 and the material relied upon in the reasons recorded under section 148(2), and the effective addition for AY 2014-15 (₹31,50,213) fell below the monetary threshold in section 149(1)(b), rendering reopening invalid. For AY 2018-19, the assessment was quashed because the order did not specify which deeming provisions (sections 68-69D) were invoked for alleged unaccounted income from accommodation entries, vitiating the assumption of jurisdiction. For AY 2021-22 the approval dated 28.06.2022 was held to be mechanically recorded ("Approved"), thus invalidating the sanction and the consequential assessment.
ITAT quashed the reassessment orders for AYs 2013-14 and 2014-15, finding jurisdictional defects: the assessing authorities failed to supply the sanction under section 151 and the material relied upon in the reasons recorded under section 148(2), and the effective addition for AY 2014-15 (₹31,50,213) fell below the monetary threshold in section 149(1)(b), rendering reopening invalid. For AY 2018-19, the assessment was quashed because the order did not specify which deeming provisions (sections 68-69D) were invoked for alleged unaccounted income from accommodation entries, vitiating the assumption of jurisdiction. For AY 2021-22 the approval dated 28.06.2022 was held to be mechanically recorded ("Approved"), thus invalidating the sanction and the consequential assessment.
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