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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u/s 263, the AO had not made any addition regarding cash deposits in the assessee company's bank account and unsecured loan received during the year under consideration, which was the basis for reopening the case u/s 147. The AO was divested of jurisdiction to make further independent additions/disallowances. The CIT could not hold the reassessment order erroneous for failing to verify independent issues. The CIT's jurisdiction u/s 263 is limited to the subject matter of reassessment. If distinct, the limitation period for section 263 starts from the original assessment order date. The CIT exceeded jurisdiction by revising the order regarding share capital/premium and unsecured loans, as these did not form the reassessment subject matter u/s 147. Hence, the CIT's revision order u/s 263 was struck down, favoring the assessee.
u/s 263, the AO had not made any addition regarding cash deposits in the assessee company's bank account and unsecured loan received during the year under consideration, which was the basis for reopening the case u/s 147. The AO was divested of jurisdiction to make further independent additions/disallowances. The CIT could not hold the reassessment order erroneous for failing to verify independent issues. The CIT's jurisdiction u/s 263 is limited to the subject matter of reassessment. If distinct, the limitation period for section 263 starts from the original assessment order date. The CIT exceeded jurisdiction by revising the order regarding share capital/premium and unsecured loans, as these did not form the reassessment subject matter u/s 147. Hence, the CIT's revision order u/s 263 was struck down, favoring the assessee.
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