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 by CIT - if the learned PCIT was of the view that the AO failed to make the necessary enquiries which should have been made during the assessment proceedings then it was a duty upon the learned PCIT to specify the relevant enquiries which should have been made but the order of the learned PCIT is silent about such enquiries which should have been made by the AO during the assessment proceedings. - Revision proceedings quashed - AT
Revision u/s 263 by CIT - if the learned PCIT was of the view that the AO failed to make the necessary enquiries which should have been made during the assessment proceedings then it was a duty upon the learned PCIT to specify the relevant enquiries which should have been made but the order of the learned PCIT is silent about such enquiries which should have been made by the AO during the assessment proceedings. - Revision proceedings quashed - AT
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