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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The ITAT upheld revision proceedings under section 263 against the assessee who claimed agricultural income exemption under section 10(1). Despite limited scrutiny focused on "larger agricultural income," the AO failed to verify the assessee's title or leasehold rights on the agricultural land. The Tribunal rejected the assessee's arguments that the PCIT should have conducted inquiries himself before terming the assessment erroneous, noting that the PCIT had clearly established a case of "no enquiry" by the AO. The ITAT found that both conditions-erroneous assessment and prejudice to Revenue's interests-were satisfied per Malabar Industries Ltd. The revision jurisdiction was properly exercised, and the appeal was decided against the assessee.
The ITAT upheld revision proceedings under section 263 against the assessee who claimed agricultural income exemption under section 10(1). Despite limited scrutiny focused on "larger agricultural income," the AO failed to verify the assessee's title or leasehold rights on the agricultural land. The Tribunal rejected the assessee's arguments that the PCIT should have conducted inquiries himself before terming the assessment erroneous, noting that the PCIT had clearly established a case of "no enquiry" by the AO. The ITAT found that both conditions-erroneous assessment and prejudice to Revenue's interests-were satisfied per Malabar Industries Ltd. The revision jurisdiction was properly exercised, and the appeal was decided against the assessee.
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