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 High Court held that the intimation u/s 143(1) of the Income Tax Act falls within the ambit of 'any orders' envisaged u/s 264, making revision maintainable against such intimation. Section 264 confers wide powers to correct errors committed by subordinate authorities or even errors by the assessee in not claiming legitimate deductions. The Commissioner has the power to condone delays to do substantial justice by disposing matters on merits. Relying on precedent, the Court ruled that revision u/s 264 is maintainable against intimations u/s 143(1).
The High Court held that the intimation u/s 143(1) of the Income Tax Act falls within the ambit of 'any orders' envisaged u/s 264, making revision maintainable against such intimation. Section 264 confers wide powers to correct errors committed by subordinate authorities or even errors by the assessee in not claiming legitimate deductions. The Commissioner has the power to condone delays to do substantial justice by disposing matters on merits. Relying on precedent, the Court ruled that revision u/s 264 is maintainable against intimations u/s 143(1).
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