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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Relevance of the valuation report received after assessment, the application of mind by the PCIT in invoking Section 263 revision jurisdiction, the treatment of valuation issues u/s 154 rectification, and the jurisdiction of the PCIT (Central), Nagpur in revision proceedings. It holds that there is no time limit for furnishing the valuation officer's report, and the PCIT had duly applied their mind before invoking Section 263. Valuation issues would not attract Section 154 rectification as per the Supreme Court's ruling. The PCIT (Central), Nagpur had jurisdiction in the revision proceedings, as the assessee failed to prove otherwise. The ITAT rejected all the assessee's arguments and decided against them.
Relevance of the valuation report received after assessment, the application of mind by the PCIT in invoking Section 263 revision jurisdiction, the treatment of valuation issues u/s 154 rectification, and the jurisdiction of the PCIT (Central), Nagpur in revision proceedings. It holds that there is no time limit for furnishing the valuation officer's report, and the PCIT had duly applied their mind before invoking Section 263. Valuation issues would not attract Section 154 rectification as per the Supreme Court's ruling. The PCIT (Central), Nagpur had jurisdiction in the revision proceedings, as the assessee failed to prove otherwise. The ITAT rejected all the assessee's arguments and decided against them.
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