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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The dominant issue was whether reassessment initiation under the post-01.04.2021 regime was barred by limitation where an earlier notice issued on 30.06.2021 under the erstwhile Section 148 was deemed to be under Section 148A(b). Applying the legal fiction in Ashish Agarwal and the clarification in Rajeev Bansal, the court held that limitation had to be tested by the surviving time under Section 149 read with TOLA, and that a fresh Section 148 notice under the new regime could be issued only if limitation under the old regime had not already expired. Since TOLA extended the old-regime six-year period up to 30.06.2021 and the escaped income exceeded Rs. 50 lakh, the 29.07.2022 notice was within time and had valid Section 151 approval; the writ was dismissed. - HC
The dominant issue was whether reassessment initiation under the post-01.04.2021 regime was barred by limitation where an earlier notice issued on 30.06.2021 under the erstwhile Section 148 was deemed to be under Section 148A(b). Applying the legal fiction in Ashish Agarwal and the clarification in Rajeev Bansal, the court held that limitation had to be tested by the surviving time under Section 149 read with TOLA, and that a fresh Section 148 notice under the new regime could be issued only if limitation under the old regime had not already expired. Since TOLA extended the old-regime six-year period up to 30.06.2021 and the escaped income exceeded Rs. 50 lakh, the 29.07.2022 notice was within time and had valid Section 151 approval; the writ was dismissed. - HC
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