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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Revision u/s 263 - the ld. PCIT had alleged that the ld. AO had not made any enquiry at all on the issue of long term borrowings and other current liabilities. It is not the case of the PCIT that the ld. AO had indeed made enquiries but he had not made requisite entries thereon - Hence, in our considered opinion, the ld. PCIT grossly erred in invoking revisionary jurisdiction which is against the settled legal principles and more so in the facts and circumstances of the instant case. - AT
Revision u/s 263 - the ld. PCIT had alleged that the ld. AO had not made any enquiry at all on the issue of long term borrowings and other current liabilities. It is not the case of the PCIT that the ld. AO had indeed made enquiries but he had not made requisite entries thereon - Hence, in our considered opinion, the ld. PCIT grossly erred in invoking revisionary jurisdiction which is against the settled legal principles and more so in the facts and circumstances of the instant case. - AT
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