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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HC upheld the validity of reassessment proceedings initiated u/s 147 against the assessee. It held that the AO had correctly formed a reason to believe that income had escaped assessment due to the assessee's failure to fully and truly disclose all material facts necessary for assessment, specifically the agreement with the Central Government required for claiming deduction u/s 42. Mere disclosure of the deduction claim in the audit report and return of income was held insufficient in the absence of the underlying agreement. Accepting the concurrent factual findings of the AO, CIT(A), and Tribunal, HC found no perversity warranting interference. The reassessment was held to be within limitation and legally sustainable. The appeal was dismissed and decided against the assessee.
HC upheld the validity of reassessment proceedings initiated u/s 147 against the assessee. It held that the AO had correctly formed a reason to believe that income had escaped assessment due to the assessee's failure to fully and truly disclose all material facts necessary for assessment, specifically the agreement with the Central Government required for claiming deduction u/s 42. Mere disclosure of the deduction claim in the audit report and return of income was held insufficient in the absence of the underlying agreement. Accepting the concurrent factual findings of the AO, CIT(A), and Tribunal, HC found no perversity warranting interference. The reassessment was held to be within limitation and legally sustainable. The appeal was dismissed and decided against the assessee.
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