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 - period of limitation - CIT may enhance, modify or cancel the assessment order and may also direct the AO to cause examination of the details and further pass an order. But he can do so only after granting assessee an opportunity of hearing. However according to the provisions of sub-section (2), such order could be passed only within the period of two years from the end of the financial year in which the order sought to be revised was passed. - AT
Revision u/s 263 - period of limitation - CIT may enhance, modify or cancel the assessment order and may also direct the AO to cause examination of the details and further pass an order. But he can do so only after granting assessee an opportunity of hearing. However according to the provisions of sub-section (2), such order could be passed only within the period of two years from the end of the financial year in which the order sought to be revised was passed. - AT
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