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 overturned PCIT's revision order under s.263 regarding treatment of income surrendered during survey. The tribunal found AO had conducted proper inquiry into excess cosmetics stock discovered during survey. AO accepted assessee's explanation that undisclosed income arose from regular business transactions, not unexplained investments. Assessee demonstrated excess stock valued at cost was Rs.17 lakhs, not Rs.50 lakhs claimed. Since AO took a legally plausible view after adequate verification that s.115BBE was inapplicable, and no evidence existed of income from sources besides cosmetics business, PCIT's revision jurisdiction was unjustified. The original assessment order was neither erroneous nor prejudicial to revenue interests. Appeal allowed in assessee's favor.
ITAT overturned PCIT's revision order under s.263 regarding treatment of income surrendered during survey. The tribunal found AO had conducted proper inquiry into excess cosmetics stock discovered during survey. AO accepted assessee's explanation that undisclosed income arose from regular business transactions, not unexplained investments. Assessee demonstrated excess stock valued at cost was Rs.17 lakhs, not Rs.50 lakhs claimed. Since AO took a legally plausible view after adequate verification that s.115BBE was inapplicable, and no evidence existed of income from sources besides cosmetics business, PCIT's revision jurisdiction was unjustified. The original assessment order was neither erroneous nor prejudicial to revenue interests. Appeal allowed in assessee's favor.
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