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 assessment order invalid for non-compliance with the mandatory procedure under Section 144C. The AO passed the final assessment order before expiry of the 30-day period prescribed in Section 144C(2) for the assessee to file objections to the draft assessment order, thereby frustrating the assessee's statutory right to approach the DRP. ITAT ruled that such breach rendered the final assessment order unsustainable in law. The final assessment order passed under Section 144C was quashed, and all additions, disallowances and the consequential tax demand raised on the assessee were deleted.
ITAT held the assessment order invalid for non-compliance with the mandatory procedure under Section 144C. The AO passed the final assessment order before expiry of the 30-day period prescribed in Section 144C(2) for the assessee to file objections to the draft assessment order, thereby frustrating the assessee's statutory right to approach the DRP. ITAT ruled that such breach rendered the final assessment order unsustainable in law. The final assessment order passed under Section 144C was quashed, and all additions, disallowances and the consequential tax demand raised on the assessee were deleted.
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