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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Reopening of assessment u/s 147 - excess claim of Deduction u/s 10B - The case of the respondent (Revenue) is that the petitioner was in the habit of making an excess claim under Section 10B of the IT Act, 1961 and this fact came to be knowledge of the Department only when a survey was conducted during March 2010. It is submitted that, this information was not available earlier when the assessment orders were passed both under Section 143(1). - the Income Tax Department would be justified in reopening the assessment u/s 148 - HC
Reopening of assessment u/s 147 - excess claim of Deduction u/s 10B - The case of the respondent (Revenue) is that the petitioner was in the habit of making an excess claim under Section 10B of the IT Act, 1961 and this fact came to be knowledge of the Department only when a survey was conducted during March 2010. It is submitted that, this information was not available earlier when the assessment orders were passed both under Section 143(1). - the Income Tax Department would be justified in reopening the assessment u/s 148 - HC
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