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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An assessment can be revised under section 263 where the Assessing Officer makes no specific enquiry or proper verification of a deduction claim or business loss claim. Mere calling for general details, without follow-up examination, does not show application of mind. On the record described, no discernible opinion had been formed on the section 54B claim or the petrol and diesel evaporation loss, so the matter was not one of change of opinion. Applying Explanation 2(a), such an assessment is treated as erroneous and prejudicial to the Revenue, and the revisional order was sustained.
An assessment can be revised under section 263 where the Assessing Officer makes no specific enquiry or proper verification of a deduction claim or business loss claim. Mere calling for general details, without follow-up examination, does not show application of mind. On the record described, no discernible opinion had been formed on the section 54B claim or the petrol and diesel evaporation loss, so the matter was not one of change of opinion. Applying Explanation 2(a), such an assessment is treated as erroneous and prejudicial to the Revenue, and the revisional order was sustained.
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