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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Where a valid search under s.132 was conducted on the assessee, the assessee could not be treated as a "third party", and the special search assessment code under ss.153A-153D was held to override the general reassessment provision in s.147; accordingly, s.147 could not be invoked to bypass the statutory machinery and limitation applicable to a searched person, and the departmental objection was rejected. Although the search-year assessment (AY corresponding to the year of search) is not within the six preceding years under s.153A, the time limit under s.153B applies to both the six years and the year of search; since the assessment was completed beyond the prescribed outer limit, it was held time-barred and void ab initio, and the assessment was quashed. - ITAT
Where a valid search under s.132 was conducted on the assessee, the assessee could not be treated as a "third party", and the special search assessment code under ss.153A-153D was held to override the general reassessment provision in s.147; accordingly, s.147 could not be invoked to bypass the statutory machinery and limitation applicable to a searched person, and the departmental objection was rejected. Although the search-year assessment (AY corresponding to the year of search) is not within the six preceding years under s.153A, the time limit under s.153B applies to both the six years and the year of search; since the assessment was completed beyond the prescribed outer limit, it was held time-barred and void ab initio, and the assessment was quashed. - ITAT
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