Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Revision u/s 263 disallowing exemption u/s 11(1) for government grant received by assessee-Trust. ITAT concluded Principal CIT did not independently apply mind by calling office records, but acted on Assessing Officer's proposal to initiate Section 263 proceedings, rendering order liable to be set aside. ITAT based on consistency principle and absence of change in facts regarding Trust receiving government grant in earlier years accepted by Revenue for Section 11 exemption eligibility. HC found no erroneous or prejudicial assessment order u/s 143(3), dismissing appeal as no substantial question of law arose from ITAT order.
Revision u/s 263 disallowing exemption u/s 11(1) for government grant received by assessee-Trust. ITAT concluded Principal CIT did not independently apply mind by calling office records, but acted on Assessing Officer's proposal to initiate Section 263 proceedings, rendering order liable to be set aside. ITAT based on consistency principle and absence of change in facts regarding Trust receiving government grant in earlier years accepted by Revenue for Section 11 exemption eligibility. HC found no erroneous or prejudicial assessment order u/s 143(3), dismissing appeal as no substantial question of law arose from ITAT order.
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