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...
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HC set aside the reassessment proceedings and quashed the sanction under section 151 insofar as they pertain to the Petitioner, holding that no income chargeable to tax has escaped assessment. The court found the asserted "reasons to believe" unsupported by cogent material: the investigation report did not list the Petitioner as a beneficiary of accommodation entries and the contested transactions were sales proceeds already offered to tax. The reasons recorded misidentified another assessee and, together with uncorrected supervisory review, demonstrated a mechanical, non-application of mind in granting sanction. Consequently, reopening was held invalid and the Petitioner succeeded.
HC set aside the reassessment proceedings and quashed the sanction under section 151 insofar as they pertain to the Petitioner, holding that no income chargeable to tax has escaped assessment. The court found the asserted "reasons to believe" unsupported by cogent material: the investigation report did not list the Petitioner as a beneficiary of accommodation entries and the contested transactions were sales proceeds already offered to tax. The reasons recorded misidentified another assessee and, together with uncorrected supervisory review, demonstrated a mechanical, non-application of mind in granting sanction. Consequently, reopening was held invalid and the Petitioner succeeded.
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