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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Reassessment proceedings were upheld as within limitation because the section 148A(b) notice was issued on 31.03.2022, and the time allowed for the assessee's response had to be excluded under the third proviso to section 149, with the balance period extended under the fourth proviso. As the reply was filed on 21.04.2022, the Assessing Officer had time until 21.05.2022 to pass the section 148A(d) order, so the 28.04.2022 order and consequential section 148 notice were timely. The Court also rejected the challenge that entries in books or survey material were not an "asset" under section 149(1)(b), holding the definition inclusive and the later amendment clarificatory.
Reassessment proceedings were upheld as within limitation because the section 148A(b) notice was issued on 31.03.2022, and the time allowed for the assessee's response had to be excluded under the third proviso to section 149, with the balance period extended under the fourth proviso. As the reply was filed on 21.04.2022, the Assessing Officer had time until 21.05.2022 to pass the section 148A(d) order, so the 28.04.2022 order and consequential section 148 notice were timely. The Court also rejected the challenge that entries in books or survey material were not an "asset" under section 149(1)(b), holding the definition inclusive and the later amendment clarificatory.
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