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 under s.263 where AO failed to conduct proper inquiry regarding rental expenses despite having incriminating WhatsApp chat evidence showing circular transactions. AO's acceptance of mere ledger entries without verifying supporting documents like rent agreements or investigating the pattern of cheque payments and cash returns demonstrated non-application of mind. The routine questionnaire was deemed insufficient for proper scrutiny. ITAT found the assessment order both erroneous and prejudicial to revenue interests due to complete lack of verification of available material evidence. PCIT's jurisdiction under s.263 was held valid as the case involved absence of effective inquiry rather than difference of opinion between two possible views. Decision affirmed against assessee.
ITAT upheld revision under s.263 where AO failed to conduct proper inquiry regarding rental expenses despite having incriminating WhatsApp chat evidence showing circular transactions. AO's acceptance of mere ledger entries without verifying supporting documents like rent agreements or investigating the pattern of cheque payments and cash returns demonstrated non-application of mind. The routine questionnaire was deemed insufficient for proper scrutiny. ITAT found the assessment order both erroneous and prejudicial to revenue interests due to complete lack of verification of available material evidence. PCIT's jurisdiction under s.263 was held valid as the case involved absence of effective inquiry rather than difference of opinion between two possible views. Decision affirmed against assessee.
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