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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Assessments pursuant to search were held time-barred under s.153B because the search legally concluded on 20.02.2021, when the authorised officer completed the physical search and drew the last valid panchanama; the later visit on 20.04.2021 merely lifted a restraint under s.132(3) without any further search activity or fresh authorisation and could not extend limitation. The restraint orders under s.132(3) were also found invalid as the records did not show why seizure was "not practicable," and, in any event, revocation beyond the CBDT-mandated one-month period rendered subsequent panchanamas incapable of extending limitation. Consequently, assessments for AYs 2020-21 and 2021-22 were quashed as barred by limitation. - ITAT
Assessments pursuant to search were held time-barred under s.153B because the search legally concluded on 20.02.2021, when the authorised officer completed the physical search and drew the last valid panchanama; the later visit on 20.04.2021 merely lifted a restraint under s.132(3) without any further search activity or fresh authorisation and could not extend limitation. The restraint orders under s.132(3) were also found invalid as the records did not show why seizure was "not practicable," and, in any event, revocation beyond the CBDT-mandated one-month period rendered subsequent panchanamas incapable of extending limitation. Consequently, assessments for AYs 2020-21 and 2021-22 were quashed as barred by limitation. - ITAT
Note: It is a system-generated summary and is for quick reference only.