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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Reopening of assessment u/s 147 - An inadvertent error committed by the Petitioner in reflecting that the return of income had been filed under the category ‘u/s 119(2)(b)’ instead of selecting the option ‘u/s 148’ could have been treated to be a return validly filed by invoking the provisions of Section 292B of the Act especially when the Petitioner claims that the mistake was brought to the notice of the concerned A.O. at the appropriate stage. - Matter restored back to AO - HC
Reopening of assessment u/s 147 - An inadvertent error committed by the Petitioner in reflecting that the return of income had been filed under the category ‘u/s 119(2)(b)’ instead of selecting the option ‘u/s 148’ could have been treated to be a return validly filed by invoking the provisions of Section 292B of the Act especially when the Petitioner claims that the mistake was brought to the notice of the concerned A.O. at the appropriate stage. - Matter restored back to AO - HC
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