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 set aside CIT(A)'s order regarding exemption u/s 10(26AAA) for Sikkimese individual's income. CIT(A) had deleted additions u/ss 69A and 69 based solely on identification certificate without following Rule 46A(3) of IT Rules, which requires AO verification. ITAT restored assessment proceedings before AO for fresh consideration, allowing assessee opportunity to present evidence supporting exemption claim. Both Revenue's counsel and assessee's representative agreed to this approach. Revenue's appeal allowed for statistical purposes. Matter remanded for verification of whether conditions u/s 10(26AAA) were fulfilled, ensuring procedural compliance and fair hearing.
ITAT set aside CIT(A)'s order regarding exemption u/s 10(26AAA) for Sikkimese individual's income. CIT(A) had deleted additions u/ss 69A and 69 based solely on identification certificate without following Rule 46A(3) of IT Rules, which requires AO verification. ITAT restored assessment proceedings before AO for fresh consideration, allowing assessee opportunity to present evidence supporting exemption claim. Both Revenue's counsel and assessee's representative agreed to this approach. Revenue's appeal allowed for statistical purposes. Matter remanded for verification of whether conditions u/s 10(26AAA) were fulfilled, ensuring procedural compliance and fair hearing.
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