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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Reopening of assessment on allegation of bogus invoices was held unjustified because ledger entries did not show escaped income and the AO treated Rs.3,67,43,973 as bogus purchase despite it being claimed as a deduction and linked to a later payment of Rs.5,13,02,342 following a DGGI survey. The petitioner was not called upon to explain the alleged bogus GST claim, and the High Court found procedural and substantive defects in the reassessment action. Consequently the notice under reopening and the impugned order were quashed and the writ petition allowed.
Reopening of assessment on allegation of bogus invoices was held unjustified because ledger entries did not show escaped income and the AO treated Rs.3,67,43,973 as bogus purchase despite it being claimed as a deduction and linked to a later payment of Rs.5,13,02,342 following a DGGI survey. The petitioner was not called upon to explain the alleged bogus GST claim, and the High Court found procedural and substantive defects in the reassessment action. Consequently the notice under reopening and the impugned order were quashed and the writ petition allowed.
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