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 - claim of deduction u/s. 54F - The fact remains that the calculations were provided to the ld. PCIT. It is seen that he has failed to find any infirmity in the claim. - PCIT, instead has set aside the order u/s. 143(3)/148 in order to grant one more inning to the Revenue to find some shortcoming in the claim on the suspicion that possibly the AO has missed something in the first round. Such an action cannot be supported. Powers u/s. 263 of the Income Tax Act are not on the Statute for such whimsical and arbitrary actions. - AT
Revision u/s 263 - claim of deduction u/s. 54F - The fact remains that the calculations were provided to the ld. PCIT. It is seen that he has failed to find any infirmity in the claim. - PCIT, instead has set aside the order u/s. 143(3)/148 in order to grant one more inning to the Revenue to find some shortcoming in the claim on the suspicion that possibly the AO has missed something in the first round. Such an action cannot be supported. Powers u/s. 263 of the Income Tax Act are not on the Statute for such whimsical and arbitrary actions. - AT
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