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 assessee, a charitable trust enjoying exemption u/s 11 since 1954, was denied exemption by the Assessing Officer during reassessment proceedings on the grounds that the assessee had not filed the return of income as mandated u/s 139(1). However, the Commissioner of Income Tax (CIT) revised the order u/s 263, deeming it bad in law. The Tribunal held that the revision was unjustified as the assessee had been granted exemption in scrutiny assessments and by the Tribunal for various assessment years. The assessee's inability to file returns electronically from 2013-14 to 2015-16 due to unavailability of registration details was a circumstance not considered properly. Despite efforts to file physical returns, they were not accepted due to lack of information. The CIT(Appeals) doubted the postal acknowledgments without verifying the assessee's submissions. Consequently, the Tribunal allowed the assessee's appeal, ruling that the revision order could not be upheld in law.
The assessee, a charitable trust enjoying exemption u/s 11 since 1954, was denied exemption by the Assessing Officer during reassessment proceedings on the grounds that the assessee had not filed the return of income as mandated u/s 139(1). However, the Commissioner of Income Tax (CIT) revised the order u/s 263, deeming it bad in law. The Tribunal held that the revision was unjustified as the assessee had been granted exemption in scrutiny assessments and by the Tribunal for various assessment years. The assessee's inability to file returns electronically from 2013-14 to 2015-16 due to unavailability of registration details was a circumstance not considered properly. Despite efforts to file physical returns, they were not accepted due to lack of information. The CIT(Appeals) doubted the postal acknowledgments without verifying the assessee's submissions. Consequently, the Tribunal allowed the assessee's appeal, ruling that the revision order could not be upheld in law.
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