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 finding assessment order erroneous and prejudicial to revenue interests. Assessee failed to establish loan genuineness and lenders' creditworthiness during initial assessment. Key factors: lenders lacked financial capacity for large interest-free loans, absence of loan confirmations, non-filing/minimal income shown in tax returns by lenders, and loans remaining unpaid without interest for extended period. Tribunal determined transactions fell outside reasonable probability, confirming their non-genuine nature. CIT's intervention justified as AO failed to conduct proper inquiry during assessment regarding loan authenticity and lenders' creditworthiness. Additional documentation provided during s.263 proceedings also failed to establish transaction legitimacy.
ITAT upheld revision under s.263 finding assessment order erroneous and prejudicial to revenue interests. Assessee failed to establish loan genuineness and lenders' creditworthiness during initial assessment. Key factors: lenders lacked financial capacity for large interest-free loans, absence of loan confirmations, non-filing/minimal income shown in tax returns by lenders, and loans remaining unpaid without interest for extended period. Tribunal determined transactions fell outside reasonable probability, confirming their non-genuine nature. CIT's intervention justified as AO failed to conduct proper inquiry during assessment regarding loan authenticity and lenders' creditworthiness. Additional documentation provided during s.263 proceedings also failed to establish transaction legitimacy.
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