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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Validity of an ex-parte revisionary order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The key points are: The PCIT passed the revisionary order after considering the assessee's submissions, refuting allegations of violating principles of natural justice. The order was within the statutory time limit of two years from the end of the relevant financial year. The PCIT had revisionary jurisdiction as the Assessing Officer's (AO) order was erroneous and prejudicial to revenue interests by not examining cash transactions exceeding Rs. 20,000, attracting disallowance u/s 40A(3). The AO's order was cryptic, lacking examination of issues mandated for scrutiny under CASS. The PCIT correctly pointed out the AO's mistakes in not disallowing expenses u/s 40A(3) and not initiating penalty proceedings u/ss 269SS, 269T, and 271D for cash loan repayments. The PCIT directed the AO to pass a fresh assessment order, including consequential penalties, without transgressing jurisdiction u/s 263.
Validity of an ex-parte revisionary order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The key points are: The PCIT passed the revisionary order after considering the assessee's submissions, refuting allegations of violating principles of natural justice. The order was within the statutory time limit of two years from the end of the relevant financial year. The PCIT had revisionary jurisdiction as the Assessing Officer's (AO) order was erroneous and prejudicial to revenue interests by not examining cash transactions exceeding Rs. 20,000, attracting disallowance u/s 40A(3). The AO's order was cryptic, lacking examination of issues mandated for scrutiny under CASS. The PCIT correctly pointed out the AO's mistakes in not disallowing expenses u/s 40A(3) and not initiating penalty proceedings u/ss 269SS, 269T, and 271D for cash loan repayments. The PCIT directed the AO to pass a fresh assessment order, including consequential penalties, without transgressing jurisdiction u/s 263.
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