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 by CIT - disallowance of provision for nonperforming assets (NPA) in computing books profits u/s 115JB - The Tribunal, after considering detailed submissions and previous judicial precedents, ruled in favor of the assessee on all major issues. It concluded that the AO had conducted proper enquiries and made permissible views under the law, rendering the Pr. CIT’s invocation of section 263 invalid. Consequently, the Tribunal quashed the order passed u/s 263 and restored the original assessment order.
Revision u/s 263 by CIT - disallowance of provision for nonperforming assets (NPA) in computing books profits u/s 115JB - The Tribunal, after considering detailed submissions and previous judicial precedents, ruled in favor of the assessee on all major issues. It concluded that the AO had conducted proper enquiries and made permissible views under the law, rendering the Pr. CIT’s invocation of section 263 invalid. Consequently, the Tribunal quashed the order passed u/s 263 and restored the original assessment order.
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