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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Distinction between "lack of inquiry and inadequate inquiry" emphasized. Assessee underwent rigorous assessment proceedings with multiple notices and replies. AO accepted returned income after due diligence, proper inquiry, and verification. Raising queries and examining records shows AO's application of mind. Entire record examined before concluding AO didn't examine any issue. Enquiry methodology prescribed followed. AO framed assessment considering assessee's replies. PCIT didn't conduct bare minimum inquiry before terming AO's order erroneous and prejudicial. Impugned PCIT order without jurisdiction, in excess of jurisdiction, irregular exercise of jurisdiction, null, void, illegal, improper exercise of revisionary jurisdiction u/s 263. Decided in assessee's favor.
Distinction between "lack of inquiry and inadequate inquiry" emphasized. Assessee underwent rigorous assessment proceedings with multiple notices and replies. AO accepted returned income after due diligence, proper inquiry, and verification. Raising queries and examining records shows AO's application of mind. Entire record examined before concluding AO didn't examine any issue. Enquiry methodology prescribed followed. AO framed assessment considering assessee's replies. PCIT didn't conduct bare minimum inquiry before terming AO's order erroneous and prejudicial. Impugned PCIT order without jurisdiction, in excess of jurisdiction, irregular exercise of jurisdiction, null, void, illegal, improper exercise of revisionary jurisdiction u/s 263. Decided in assessee's favor.
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