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 quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since statutory conditions were not satisfied. Consequently, the extended time limit under s.153A was inapplicable, rendering the assessments invalid due to limitation. However, regarding additions under s.69 for unexplained payments, the Tribunal upheld the CIT(A)'s decision sustaining the AO's additions, noting the 4-year gap between alleged advance receipts and payments, and the appellant's failure to establish the source of payments from known income sources.
The ITAT quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since statutory conditions were not satisfied. Consequently, the extended time limit under s.153A was inapplicable, rendering the assessments invalid due to limitation. However, regarding additions under s.69 for unexplained payments, the Tribunal upheld the CIT(A)'s decision sustaining the AO's additions, noting the 4-year gap between alleged advance receipts and payments, and the appellant's failure to establish the source of payments from known income sources.
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