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 - The subject matter of the deduction in the reassessment order was the quantum of deduction but not the eligibility of the deduction and even in that case also the deduction pertaining to MBF unit but not other units whereas the revisionary proceedings dealt extensively with the eligibility of the deduction per se maintenance of separate books of accounts change of opinion by the CIT where the Ld. CIT and also the contrary reviews taken by the DRP for the successive assessment years allowing the deduction. The revisionary proceedings cannot go beyond the issue of the reassessment proceedings. - AT
Revision u/s 263 by CIT - The subject matter of the deduction in the reassessment order was the quantum of deduction but not the eligibility of the deduction and even in that case also the deduction pertaining to MBF unit but not other units whereas the revisionary proceedings dealt extensively with the eligibility of the deduction per se maintenance of separate books of accounts change of opinion by the CIT where the Ld. CIT and also the contrary reviews taken by the DRP for the successive assessment years allowing the deduction. The revisionary proceedings cannot go beyond the issue of the reassessment proceedings. - AT
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