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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The ITAT, an Appellate Tribunal, considered a case involving a revision u/s 263 by the CIT regarding the eligibility to claim deduction u/s 80G for donations made under CSR activities. The ITAT held that the Principal CIT should conduct necessary inquiries before deeming the AO's order as erroneous. It was emphasized that if queries were raised during assessment and responded to by the assessee, it does not imply a lack of application of mind by the AO. The ITAT found the assessee eligible for the deduction u/s 80G, with no dispute on the genuineness of contributions. As the AO had applied his mind and verified facts, the ITAT set aside the CIT's order, ruling in favor of the assessee.
The ITAT, an Appellate Tribunal, considered a case involving a revision u/s 263 by the CIT regarding the eligibility to claim deduction u/s 80G for donations made under CSR activities. The ITAT held that the Principal CIT should conduct necessary inquiries before deeming the AO's order as erroneous. It was emphasized that if queries were raised during assessment and responded to by the assessee, it does not imply a lack of application of mind by the AO. The ITAT found the assessee eligible for the deduction u/s 80G, with no dispute on the genuineness of contributions. As the AO had applied his mind and verified facts, the ITAT set aside the CIT's order, ruling in favor of the assessee.
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