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 quashed the addition made under s.143(3) read with s.263, as the underlying revision order by Pr. CIT under s.263 was previously set aside. The Tribunal found that AO had conducted proper inquiry regarding interest treatment during scrutiny assessment. The difference between Form 26AS and ITR amounts was explained by interest received from banks being adjusted against project expenditure in company's financial statements. The assessee's explanation was accepted by AO during original assessment. Since the foundational s.263 revision order was invalidated, the subsequent addition made pursuant to it could not sustain. ITAT vacated the addition and set aside CIT(A)'s order upholding it.
ITAT quashed the addition made under s.143(3) read with s.263, as the underlying revision order by Pr. CIT under s.263 was previously set aside. The Tribunal found that AO had conducted proper inquiry regarding interest treatment during scrutiny assessment. The difference between Form 26AS and ITR amounts was explained by interest received from banks being adjusted against project expenditure in company's financial statements. The assessee's explanation was accepted by AO during original assessment. Since the foundational s.263 revision order was invalidated, the subsequent addition made pursuant to it could not sustain. ITAT vacated the addition and set aside CIT(A)'s order upholding it.
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