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 CPC correctly processed the return of income u/s 143(1)(a)(ii) read with Explanation (a)(i) and (a)(ii). The assessee failed to report agricultural income of Rs. 1,15,69,580 as exempt in Schedule-EI. Despite a proposed adjustment communication, the assessee did not respond within 30 days. The CPC was justified in making the adjustment as the claim was inconsistent with the return. Rectification u/s 154 is not obligatory if clear data is unavailable, relying on Anchor Processing Pvt. Ltd. The assessee did not revise the return u/s 139(5). The appeal against the section 154 order has a narrow scope, precluding merit examination. The assessee conceded the mistake before CIT(A), leaving no arguable case. No patent error amenable for rectification exists, warranting dismissal of all grounds raised.
The CPC correctly processed the return of income u/s 143(1)(a)(ii) read with Explanation (a)(i) and (a)(ii). The assessee failed to report agricultural income of Rs. 1,15,69,580 as exempt in Schedule-EI. Despite a proposed adjustment communication, the assessee did not respond within 30 days. The CPC was justified in making the adjustment as the claim was inconsistent with the return. Rectification u/s 154 is not obligatory if clear data is unavailable, relying on Anchor Processing Pvt. Ltd. The assessee did not revise the return u/s 139(5). The appeal against the section 154 order has a narrow scope, precluding merit examination. The assessee conceded the mistake before CIT(A), leaving no arguable case. No patent error amenable for rectification exists, warranting dismissal of all grounds raised.
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