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 case pertains to revision u/s 263 regarding adjustment made in profit on account of tangible fixed assets. The assessee's audited financial statements indicated an increase in profit as per ICDS-V (tangible fixed assets). However, the Assessing Officer (AO) failed to add back the impugned amount despite the auditors' recommendation. The Commissioner of Income Tax (CIT) provisionally computed excess depreciation granted at 15%. The Appellate Tribunal held that the accounts' working of depreciation chargeable under the profit and loss account was correctly worked out and disclosed in the audit report filed with the return of income. The AO considered the assessee's explanation and dropped any adverse treatment. The CIT erroneously failed to consider the details in the audit report, leading to an erroneous conclusion. The order was quashed, and the decision was in favor of the assessee.
The case pertains to revision u/s 263 regarding adjustment made in profit on account of tangible fixed assets. The assessee's audited financial statements indicated an increase in profit as per ICDS-V (tangible fixed assets). However, the Assessing Officer (AO) failed to add back the impugned amount despite the auditors' recommendation. The Commissioner of Income Tax (CIT) provisionally computed excess depreciation granted at 15%. The Appellate Tribunal held that the accounts' working of depreciation chargeable under the profit and loss account was correctly worked out and disclosed in the audit report filed with the return of income. The AO considered the assessee's explanation and dropped any adverse treatment. The CIT erroneously failed to consider the details in the audit report, leading to an erroneous conclusion. The order was quashed, and the decision was in favor of the assessee.
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