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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ITAT upheld revision proceedings u/s 263 regarding undisclosed property transactions discovered during recovery proceedings. The assessee had failed to report capital gains from three properties and subsequently acknowledged these transactions. Though initially captioned as a proposal u/s 263, the AO's information was deemed valid grounds for PCIT's intervention. The jurisdictional challenge regarding PCIT-21 versus PCIT-12's authority was rejected, as current jurisdiction lay with PCIT-12 when proceedings were initiated on 22.02.2021. The assessee's prior agreement to settle and subsequent failure to provide documentation within the stipulated timeframe further supported PCIT's findings. Appeal dismissed.
ITAT upheld revision proceedings u/s 263 regarding undisclosed property transactions discovered during recovery proceedings. The assessee had failed to report capital gains from three properties and subsequently acknowledged these transactions. Though initially captioned as a proposal u/s 263, the AO's information was deemed valid grounds for PCIT's intervention. The jurisdictional challenge regarding PCIT-21 versus PCIT-12's authority was rejected, as current jurisdiction lay with PCIT-12 when proceedings were initiated on 22.02.2021. The assessee's prior agreement to settle and subsequent failure to provide documentation within the stipulated timeframe further supported PCIT's findings. Appeal dismissed.
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