Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
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