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 by CIT - Addition u/s 68 - unexplained credit - The Tribunal meticulously examined the submissions, the audit objections, and the law's provisions. It observed that the appellant had indeed furnished comprehensive details during the original assessment proceedings. Notably, the Tribunal found that the Pr.CIT's reliance on audit objections and the subsequent show cause notice under Section 263 lacked independent application of mind. - The Tribunal held that the original assessment order made after due inquiries by the AO, which included scrutiny of unsecured loans and trade payables, could not be deemed erroneous merely because the Pr.CIT had a different view.
Revision u/s 263 by CIT - Addition u/s 68 - unexplained credit - The Tribunal meticulously examined the submissions, the audit objections, and the law's provisions. It observed that the appellant had indeed furnished comprehensive details during the original assessment proceedings. Notably, the Tribunal found that the Pr.CIT's reliance on audit objections and the subsequent show cause notice under Section 263 lacked independent application of mind. - The Tribunal held that the original assessment order made after due inquiries by the AO, which included scrutiny of unsecured loans and trade payables, could not be deemed erroneous merely because the Pr.CIT had a different view.
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