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 - Even if we agrees to the contention of the Ld. A.R. of the assessee that Explanation 2(c ) below section 263(1) of the Act is not applicable for AY 2014-15, still it does not in any way make any impact on the finding made by the Ld. PCIT that the AO has not enquired into the five (5) issues raised by him in the SCN - we uphold the action of the Ld. PCIT to have invoked Section 263 of the Act to interdict the assessment order - AT
Revision u/s 263 by CIT - Even if we agrees to the contention of the Ld. A.R. of the assessee that Explanation 2(c ) below section 263(1) of the Act is not applicable for AY 2014-15, still it does not in any way make any impact on the finding made by the Ld. PCIT that the AO has not enquired into the five (5) issues raised by him in the SCN - we uphold the action of the Ld. PCIT to have invoked Section 263 of the Act to interdict the assessment order - AT
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