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 - Reopening of assessment initiated against assessee - Since in the instant case the AO has conducted due enquiry and after being satisfied, accepted the returned income and passed the order under section 143(3)/147 therefore, the order cannot be called as an erroneous order. Therefore, even if the order is prejudicial to the interests of Revenue, but, the same not being erroneous, the twin conditions are not satisfied - AT
Revision u/s 263 - Reopening of assessment initiated against assessee - Since in the instant case the AO has conducted due enquiry and after being satisfied, accepted the returned income and passed the order under section 143(3)/147 therefore, the order cannot be called as an erroneous order. Therefore, even if the order is prejudicial to the interests of Revenue, but, the same not being erroneous, the twin conditions are not satisfied - AT
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