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 - Exemption u/s 11 - Mere statement in the appeal filed by the Revenue before this Court that “no documentary evidence is submitted by the assessee in support of its claim” cannot be countenanced in view of categorical finding of fact by the AO as also the learned ITAT that the assessee-respondent did furnish statements, documents and details as sought for in compliance of notice issued for assessment u/s 143 of the IT Act before the Assessing Officer. - Revision not valid - HC
Revision u/s 263 - Exemption u/s 11 - Mere statement in the appeal filed by the Revenue before this Court that “no documentary evidence is submitted by the assessee in support of its claim” cannot be countenanced in view of categorical finding of fact by the AO as also the learned ITAT that the assessee-respondent did furnish statements, documents and details as sought for in compliance of notice issued for assessment u/s 143 of the IT Act before the Assessing Officer. - Revision not valid - HC
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