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 - Assessee has regular dealings with these related persons/entities and necessary confirmation is on record and therefore, the findings of the ld PCIT that no documents have been filed by the assessee is not borne out of records. As regarding, the advances given by the assessee during the year, the assessee during the assessment proceedings has submitted that no advances were given during the year and therefore, the findings of the ld PCIT is again not borne out of records. - Order passed u/s 263 set aside - AT
Revision u/s 263 - Assessee has regular dealings with these related persons/entities and necessary confirmation is on record and therefore, the findings of the ld PCIT that no documents have been filed by the assessee is not borne out of records. As regarding, the advances given by the assessee during the year, the assessee during the assessment proceedings has submitted that no advances were given during the year and therefore, the findings of the ld PCIT is again not borne out of records. - Order passed u/s 263 set aside - AT
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