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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PCIT issued revision notice under s263 based on audit objections regarding unexplained property investments and bank deposits. The second notice dated 17.2.2022 introducing new issues exceeded statutory two-year limitation period. AO had previously examined property investments and ICICI bank account through s148 proceedings, conducting specific inquiries with documented evidence. ITAT determined this wasn't a case of inadequate inquiry as AO had performed necessary investigations and maintained proper records. Following precedents from SC and ITAT Chandigarh, the revision proceedings were deemed invalid both procedurally and substantively. The PCIT's order was quashed, and assessee's appeal was allowed, confirming that AO's original assessment addressing both disputed issues was proper and complete.
PCIT issued revision notice under s263 based on audit objections regarding unexplained property investments and bank deposits. The second notice dated 17.2.2022 introducing new issues exceeded statutory two-year limitation period. AO had previously examined property investments and ICICI bank account through s148 proceedings, conducting specific inquiries with documented evidence. ITAT determined this wasn't a case of inadequate inquiry as AO had performed necessary investigations and maintained proper records. Following precedents from SC and ITAT Chandigarh, the revision proceedings were deemed invalid both procedurally and substantively. The PCIT's order was quashed, and assessee's appeal was allowed, confirming that AO's original assessment addressing both disputed issues was proper and complete.
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