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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In absence of a recorded satisfaction note by Revenue, the notice date (27.05.2022) was treated as the deemed date of search for the non-searched person, fixing the deemed year of search as F.Y. 2022-23 (A.Y. 2023-24) and thus establishing the ten-year limitation block from A.Y. 2023-24 back to A.Y. 2014-15; because A.Y. 2012-13 fell outside that block the Assessing Officer lacked jurisdiction under section 153C and the assessment framed on 03.02.2023 was time-barred and was quashed, with other grounds left open.
In absence of a recorded satisfaction note by Revenue, the notice date (27.05.2022) was treated as the deemed date of search for the non-searched person, fixing the deemed year of search as F.Y. 2022-23 (A.Y. 2023-24) and thus establishing the ten-year limitation block from A.Y. 2023-24 back to A.Y. 2014-15; because A.Y. 2012-13 fell outside that block the Assessing Officer lacked jurisdiction under section 153C and the assessment framed on 03.02.2023 was time-barred and was quashed, with other grounds left open.
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