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 - When the order of the AO suffers from a complete lack of enquiry, then the above said principle has no application due to the obvious reason that the AO has not taken a view by conducting a proper enquiry and further the acceptance of claim by the AO without conducting an enquiry would not be regarded as a possible view on the issue. When the AO has not even taken up many of the issues raised by the Pr. CIT in the show cause notice, then the case of the assessee does not fall in the category of taking a possible view by the AO - AT
Revision u/s 263 - When the order of the AO suffers from a complete lack of enquiry, then the above said principle has no application due to the obvious reason that the AO has not taken a view by conducting a proper enquiry and further the acceptance of claim by the AO without conducting an enquiry would not be regarded as a possible view on the issue. When the AO has not even taken up many of the issues raised by the Pr. CIT in the show cause notice, then the case of the assessee does not fall in the category of taking a possible view by the AO - AT
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