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 allowed assessee's appeal against revision proceedings under s.263 concerning 100% deduction claimed under s.80IC. PCIT's revision order was set aside as it failed to demonstrate how AO's inquiry was inadequate or unreasonable. AO had conducted proper verification by issuing notices, examining submissions and documentation before allowing the deduction claim. The assessment order's brevity alone does not justify revision jurisdiction when assessment records show due application of mind. ITAT held that AO's conclusion allowing 100% deduction was a plausible view that a prudent officer could take, and mere desire for re-verification cannot render the order erroneous or prejudicial to Revenue's interests under s.263.
ITAT allowed assessee's appeal against revision proceedings under s.263 concerning 100% deduction claimed under s.80IC. PCIT's revision order was set aside as it failed to demonstrate how AO's inquiry was inadequate or unreasonable. AO had conducted proper verification by issuing notices, examining submissions and documentation before allowing the deduction claim. The assessment order's brevity alone does not justify revision jurisdiction when assessment records show due application of mind. ITAT held that AO's conclusion allowing 100% deduction was a plausible view that a prudent officer could take, and mere desire for re-verification cannot render the order erroneous or prejudicial to Revenue's interests under s.263.
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