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 holds that reassessment notices issued between 1 Apr 2021 and 30 Jun 2021 under the pre-existing regime are to be treated as deemed show-cause notices under the new reassessment law, with the residual limitation computed up to 30 Jun 2021 under TOLA. For valid exercise of jurisdiction under s.148 of the new regime, the AO must issue notices within the surviving period read with s.149(1) and obtain prior approval under s.151; non-compliance renders the notice and consequential assessment void. Consequently, the s.148A(d) order dated 25.07.2022, the s.148 notice dated 25.07.2022 and the assessment order purportedly passed on 22.05.2023 are set aside.
The HC holds that reassessment notices issued between 1 Apr 2021 and 30 Jun 2021 under the pre-existing regime are to be treated as deemed show-cause notices under the new reassessment law, with the residual limitation computed up to 30 Jun 2021 under TOLA. For valid exercise of jurisdiction under s.148 of the new regime, the AO must issue notices within the surviving period read with s.149(1) and obtain prior approval under s.151; non-compliance renders the notice and consequential assessment void. Consequently, the s.148A(d) order dated 25.07.2022, the s.148 notice dated 25.07.2022 and the assessment order purportedly passed on 22.05.2023 are set aside.
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