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 - Unexplained investments in foreign financial - First and foremost this was not the purpose for the limited scrutiny assessment, which only required the AO to inquire whether the investment were duly disclosed. The AO having examined the same, he was not required to go beyond the stated purpose. The assessment order cannot be said to be erroneous therefore for not having examined an issue which it was not required to. - AT
Revision u/s 263 by CIT - Unexplained investments in foreign financial - First and foremost this was not the purpose for the limited scrutiny assessment, which only required the AO to inquire whether the investment were duly disclosed. The AO having examined the same, he was not required to go beyond the stated purpose. The assessment order cannot be said to be erroneous therefore for not having examined an issue which it was not required to. - AT
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