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 - Bogus LTCG/Share transaction - as per CIT AO failed to make necessary enquiries to ascertain the actual strength of the company, investment profile of the assessee - The Tribunal upheld the jurisdiction of the PCIT under section 263, emphasizing the lack of adequate examination of facts in the AO's assessment order. It concurred with the PCIT's finding that the AO failed to conduct necessary inquiries, leading to an erroneous assessment order. However, the Tribunal dismissed the allegation of violation of principles of natural justice, noting that the assessee was provided with opportunities to be heard.
Revision u/s 263 - Bogus LTCG/Share transaction - as per CIT AO failed to make necessary enquiries to ascertain the actual strength of the company, investment profile of the assessee - The Tribunal upheld the jurisdiction of the PCIT under section 263, emphasizing the lack of adequate examination of facts in the AO's assessment order. It concurred with the PCIT's finding that the AO failed to conduct necessary inquiries, leading to an erroneous assessment order. However, the Tribunal dismissed the allegation of violation of principles of natural justice, noting that the assessee was provided with opportunities to be heard.
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