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 Assessing Officer (AO) issued a corrigendum correcting the total income in the original assessment order. The AO has the power to withdraw, modify or substitute an assessment order with another. The corrigendum rectified an error in the preamble of the original assessment order, making it legally valid. The corrected assessment order matched the computation sheet and demand notice accompanying the original order. The Supreme Court's decision in Kalyankumar Ray supports the Revenue's case, as the AO rectified a mistake by issuing the corrigendum, which is a valid assessment order. The CIT(A)'s finding was reversed, and the matter was restored to the CIT(A) for adjudication on merits after allowing the assessee a reasonable opportunity of being heard.
The Assessing Officer (AO) issued a corrigendum correcting the total income in the original assessment order. The AO has the power to withdraw, modify or substitute an assessment order with another. The corrigendum rectified an error in the preamble of the original assessment order, making it legally valid. The corrected assessment order matched the computation sheet and demand notice accompanying the original order. The Supreme Court's decision in Kalyankumar Ray supports the Revenue's case, as the AO rectified a mistake by issuing the corrigendum, which is a valid assessment order. The CIT(A)'s finding was reversed, and the matter was restored to the CIT(A) for adjudication on merits after allowing the assessee a reasonable opportunity of being heard.
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