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 second reassessment u/s 147, initiated by notice u/s 148 dated 20/03/2020 on the same material and issues already examined and accepted in the earlier reassessment order u/s 143(3) r.w.s. 147 dated 28/11/2019, to be invalid as a mere change of opinion, following the SC ruling in Kelvinator. No new tangible material or independent enquiry was found. Consequently, the reassessment proceedings and additions treating LTCG as bogus and taxing it as unexplained money u/s 69A r.w.s. 115BBE were quashed. On merits also, in light of SEBI's final report exonerating the scrip, exemption u/s 10(38) was upheld and Revenue's case failed.
ITAT held the second reassessment u/s 147, initiated by notice u/s 148 dated 20/03/2020 on the same material and issues already examined and accepted in the earlier reassessment order u/s 143(3) r.w.s. 147 dated 28/11/2019, to be invalid as a mere change of opinion, following the SC ruling in Kelvinator. No new tangible material or independent enquiry was found. Consequently, the reassessment proceedings and additions treating LTCG as bogus and taxing it as unexplained money u/s 69A r.w.s. 115BBE were quashed. On merits also, in light of SEBI's final report exonerating the scrip, exemption u/s 10(38) was upheld and Revenue's case failed.
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