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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Whether an assessee may file an updated return under Section 139(8A) once assessment proceedings are pending: the court interpreted clause (b) of the third proviso to s.139(8A) to allow no updated return for the relevant year where assessment/reassessment/recomputation or revision proceedings are pending or completed; therefore the AO correctly refused the updated ITR request after initiation of s.143(2)/assessment u/s 143(3) r/w s.144B and proceeded to disallow exemptions and deductions on merits - request rejected and assessment sustained; appellate remedy preserved. - HC
Whether an assessee may file an updated return under Section 139(8A) once assessment proceedings are pending: the court interpreted clause (b) of the third proviso to s.139(8A) to allow no updated return for the relevant year where assessment/reassessment/recomputation or revision proceedings are pending or completed; therefore the AO correctly refused the updated ITR request after initiation of s.143(2)/assessment u/s 143(3) r/w s.144B and proceeded to disallow exemptions and deductions on merits - request rejected and assessment sustained; appellate remedy preserved. - HC
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