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 - - in the present appeals, the assessment orders have already been cancelled – meaning thereby it has extinguished, and therefore, no subsequent further proceedings can be initiated - Commissioner has committed an error by holding that “since the Revenue wants to keep the issue alive, it is necessary to pass such order”. Therefore, in view of the above discussions, the impugned orders are not sustainable in these assessment years. - AT
Revision u/s 263 by CIT - - in the present appeals, the assessment orders have already been cancelled – meaning thereby it has extinguished, and therefore, no subsequent further proceedings can be initiated - Commissioner has committed an error by holding that “since the Revenue wants to keep the issue alive, it is necessary to pass such order”. Therefore, in view of the above discussions, the impugned orders are not sustainable in these assessment years. - AT
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