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 - Receipt of corpus donation - donor itself is registered as a charitable trust/society under section 12AA of the Act. Therefore, there cannot be any doubt regarding the genuineness of the donor. Thus, the allegation of learned CIT that AO has not made proper inquiry with regard to the receipt of corpus donation is found to be contrary to facts and materials on record - AO, having passed the assessment order after conducting proper inquiry and applying his mind with due diligence - such assessment order cannot be considered to be erroneous and prejudicial to the interest of Revenue - AT
Revision u/s 263 - Exemption u/s 11 - Receipt of corpus donation - donor itself is registered as a charitable trust/society under section 12AA of the Act. Therefore, there cannot be any doubt regarding the genuineness of the donor. Thus, the allegation of learned CIT that AO has not made proper inquiry with regard to the receipt of corpus donation is found to be contrary to facts and materials on record - AO, having passed the assessment order after conducting proper inquiry and applying his mind with due diligence - such assessment order cannot be considered to be erroneous and prejudicial to the interest of Revenue - AT
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