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 under s.263 concerning genuineness of sundry creditors. AO initially questioned transactions with 10 creditors but made additions under s.41(1) for only 2 parties, failing to examine remaining 8 creditors without justification. Assessee's non-compliance in furnishing requisite details during assessment and discrepancy in ledger account of AJS Impex Pvt Ltd (showing credit balance contrary to noted debit balance) demonstrated inadequate verification. Order under s.143(3) r.w.s. 144B deemed erroneous as it lacked comprehensive inquiry mandated by Explanation 2 to s.263. AO's selective treatment of similar transactions without reasoned basis constituted jurisdictional error warranting revision.
ITAT upheld revision proceedings under s.263 concerning genuineness of sundry creditors. AO initially questioned transactions with 10 creditors but made additions under s.41(1) for only 2 parties, failing to examine remaining 8 creditors without justification. Assessee's non-compliance in furnishing requisite details during assessment and discrepancy in ledger account of AJS Impex Pvt Ltd (showing credit balance contrary to noted debit balance) demonstrated inadequate verification. Order under s.143(3) r.w.s. 144B deemed erroneous as it lacked comprehensive inquiry mandated by Explanation 2 to s.263. AO's selective treatment of similar transactions without reasoned basis constituted jurisdictional error warranting revision.
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