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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Computation of the block period for assessment under search-assessment provisions was determined by the date the non-searched assessee received seized documents or, where handing-over date is unavailable, by the date of issuance of the AOs satisfaction note; consequently the relevant block period placed AY 2015-16 in the 9th year. The statutory monetary threshold for issuing notices beyond the six-year block requires escaped income represented by assets of Rs.50 lakhs or more; since AOs quantified escaped income was Rs.8,84,540 (below the threshold), the extended-year notice was invalid and appellate relief for the assessee was affirmed.
Computation of the block period for assessment under search-assessment provisions was determined by the date the non-searched assessee received seized documents or, where handing-over date is unavailable, by the date of issuance of the AOs satisfaction note; consequently the relevant block period placed AY 2015-16 in the 9th year. The statutory monetary threshold for issuing notices beyond the six-year block requires escaped income represented by assets of Rs.50 lakhs or more; since AOs quantified escaped income was Rs.8,84,540 (below the threshold), the extended-year notice was invalid and appellate relief for the assessee was affirmed.
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