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- AO is first an investigating officer thereafter he is an adjudicator but here in this case, the AO remained silent, but, he ought to have exercised his duty properly. We find substance in the submissions made by the ld. DR. The arguments of the AR is rejected in regard to show cause notice and finding of the Pr. CIT is different because the issues are the loss on assigned portfolio. and the Pr. CIT has rightly exercised his jurisdiction vested u/s 263 and set aside the order of AO - AT
Revision u/s 263 by CIT- AO is first an investigating officer thereafter he is an adjudicator but here in this case, the AO remained silent, but, he ought to have exercised his duty properly. We find substance in the submissions made by the ld. DR. The arguments of the AR is rejected in regard to show cause notice and finding of the Pr. CIT is different because the issues are the loss on assigned portfolio. and the Pr. CIT has rightly exercised his jurisdiction vested u/s 263 and set aside the order of AO - AT
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