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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Revision u/s 263 - taxability of interest under section 28 of Land Acquisition Act - ‘no enquiry’ or ‘lack of enquiry’ - The ITAT held that, the opinion of the Ld. PCIT that the Ld. AO should have passed the assessment in accordance with the amended law and binding decision in Mahender Pal Narang’s case [2020 (3) TMI 1115 - PUNJAB AND HARYANA HIGH COURT] overlooking the decision of Hon’ble Supreme Court in Ghanshyam’s HUF’s [2009 (7) TMI 12 - SUPREME COURT] case is not sustainable. - The ITAT further observed that, it can at best be said to be a debatable issue on which two views are possible and the Ld. AO accepts one of the views. - Revision order quashed.
Revision u/s 263 - taxability of interest under section 28 of Land Acquisition Act - ‘no enquiry’ or ‘lack of enquiry’ - The ITAT held that, the opinion of the Ld. PCIT that the Ld. AO should have passed the assessment in accordance with the amended law and binding decision in Mahender Pal Narang’s case [2020 (3) TMI 1115 - PUNJAB AND HARYANA HIGH COURT] overlooking the decision of Hon’ble Supreme Court in Ghanshyam’s HUF’s [2009 (7) TMI 12 - SUPREME COURT] case is not sustainable. - The ITAT further observed that, it can at best be said to be a debatable issue on which two views are possible and the Ld. AO accepts one of the views. - Revision order quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
