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 held the notice issued u/s 143(2) invalid as it mentioned only "computer aided scrutiny selection" without specifying whether the case was under limited, complete, or compulsory manual scrutiny, contrary to binding CBDT instructions. Non-compliance with such instructions vitiated the jurisdiction assumed by the AO. Consequently, the assessment framed pursuant to the defective notice was declared void and quashed in entirety. The Tribunal followed its earlier coordinate bench ruling in a similar fact situation, and allowed the assessee's appeal, annulling the impugned assessment proceedings.
ITAT held the notice issued u/s 143(2) invalid as it mentioned only "computer aided scrutiny selection" without specifying whether the case was under limited, complete, or compulsory manual scrutiny, contrary to binding CBDT instructions. Non-compliance with such instructions vitiated the jurisdiction assumed by the AO. Consequently, the assessment framed pursuant to the defective notice was declared void and quashed in entirety. The Tribunal followed its earlier coordinate bench ruling in a similar fact situation, and allowed the assessee's appeal, annulling the impugned assessment proceedings.
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