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 u/s 147 - period of limitation - these issues are not such which can render the assessment erroneous. Similarly what prejudice is caused to the revenue is also not clear from the order of the ld PCIT. In order to revise the order the twin conditions have to be satisfied i.e. the order has to be erroneous and secondly it must be prejudicial to the interest of the revenue. - AT
Revision u/s 263 - reopening of assessment u/s 147 - period of limitation - these issues are not such which can render the assessment erroneous. Similarly what prejudice is caused to the revenue is also not clear from the order of the ld PCIT. In order to revise the order the twin conditions have to be satisfied i.e. the order has to be erroneous and secondly it must be prejudicial to the interest of the revenue. - AT
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