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 invalidated reassessment proceedings under s.147 and subsequent revision under s.263 concerning alleged accommodation entries treated as long-term capital gains. The AO's reasons for reopening were found mechanical, vague, and incomplete, lacking independent verification of information and proper inquiry. The notice under s.148 was deemed legally defective as the AO failed to specify details of alleged penny stock transactions and capital gains. Since the underlying reassessment order under s.144 r.w.s 144B was invalid, the subsequent revision proceedings initiated by Pr. CIT under s.263 were also quashed. The tribunal upheld taxpayer's additional grounds of appeal, emphasizing the importance of proper reasoning and verification in reassessment proceedings.
ITAT invalidated reassessment proceedings under s.147 and subsequent revision under s.263 concerning alleged accommodation entries treated as long-term capital gains. The AO's reasons for reopening were found mechanical, vague, and incomplete, lacking independent verification of information and proper inquiry. The notice under s.148 was deemed legally defective as the AO failed to specify details of alleged penny stock transactions and capital gains. Since the underlying reassessment order under s.144 r.w.s 144B was invalid, the subsequent revision proceedings initiated by Pr. CIT under s.263 were also quashed. The tribunal upheld taxpayer's additional grounds of appeal, emphasizing the importance of proper reasoning and verification in reassessment proceedings.
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