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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Time lost by the assessing officer during search-related handover of books of account is excluded from the 180-day limitation under the relevant provision, but only to the extent that the handover period is included in the original limitation period; consequently the excluded period (1/4/2023-22/8/2023, 144 days) extends the assessment deadline to 22/8/2024. The assessment order dated 27/9/2024 was therefore beyond the extended limitation and is time barred, and the assessee's appeal is allowed.
Time lost by the assessing officer during search-related handover of books of account is excluded from the 180-day limitation under the relevant provision, but only to the extent that the handover period is included in the original limitation period; consequently the excluded period (1/4/2023-22/8/2023, 144 days) extends the assessment deadline to 22/8/2024. The assessment order dated 27/9/2024 was therefore beyond the extended limitation and is time barred, and the assessee's appeal is allowed.
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