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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Validity of Revision u/s 263 - The Pr. CIT had argued that the original assessments were inadequate and missed critical checks, which purportedly rendered the assessments erroneous and adverse to revenue interests. However, the tribunal found that the assessee had provided sufficient documentation and explanations initially and during the re-assessment proceedings, which were conducted thoroughly by the assessing officer. The tribunal, therefore, set aside the revisional order issued by the Pr. CIT, reinstating the original assessment.
Validity of Revision u/s 263 - The Pr. CIT had argued that the original assessments were inadequate and missed critical checks, which purportedly rendered the assessments erroneous and adverse to revenue interests. However, the tribunal found that the assessee had provided sufficient documentation and explanations initially and during the re-assessment proceedings, which were conducted thoroughly by the assessing officer. The tribunal, therefore, set aside the revisional order issued by the Pr. CIT, reinstating the original assessment.
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