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 reopening/reassessment - The tribunal found that the reasons recorded by the AO for reopening the assessment were not sufficient and valid, as they merely called for detailed verification and enquiry. Relying on the judicial precedents of PCIT vs. Manzil Dinesh Kumar Shah and PCIT vs. Maheswari Devi, the tribunal concluded that such reasons do not meet the statutory requirements for reopening. Consequently, the reassessment was quashed, rendering other issues academic.
Validity of reopening/reassessment - The tribunal found that the reasons recorded by the AO for reopening the assessment were not sufficient and valid, as they merely called for detailed verification and enquiry. Relying on the judicial precedents of PCIT vs. Manzil Dinesh Kumar Shah and PCIT vs. Maheswari Devi, the tribunal concluded that such reasons do not meet the statutory requirements for reopening. Consequently, the reassessment was quashed, rendering other issues academic.
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