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 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the petitioner had adequately addressed the AO's queries regarding the deduction claim during the original assessment. Additionally, the court noted that the petitioner had not claimed any deduction for rural advances, contradicting the basis for the alleged escapement of income. - The court deemed the reopening of the assessment as a clear case of change of opinion by the AO, which did not justify reassessment.
Reopening of assessment u/s 147 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the petitioner had adequately addressed the AO's queries regarding the deduction claim during the original assessment. Additionally, the court noted that the petitioner had not claimed any deduction for rural advances, contradicting the basis for the alleged escapement of income. - The court deemed the reopening of the assessment as a clear case of change of opinion by the AO, which did not justify reassessment.
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