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 the PCIT's revision under s.263, finding the AO's assessment order erroneous and prejudicial to revenue interests. The Tribunal confirmed the AO failed to conduct proper inquiry regarding TDS compliance on expenses exceeding Rs.31 crore potentially covered under ss.194C, 194J, and 192, and did not examine s.40(a)(ia) implications. However, the ITAT modified the PCIT's direction for blanket 30% disallowance of expenses, instructing the AO to verify whether TDS was required on daily wages and labor charges, allowing expenses below threshold limits. The Tribunal also confirmed the addition under s.50C as the difference between stamp duty value and sale consideration was 9.02%, exceeding the then-applicable tolerance limit of 5%. The assessee's appeal was partly allowed.
The ITAT upheld the PCIT's revision under s.263, finding the AO's assessment order erroneous and prejudicial to revenue interests. The Tribunal confirmed the AO failed to conduct proper inquiry regarding TDS compliance on expenses exceeding Rs.31 crore potentially covered under ss.194C, 194J, and 192, and did not examine s.40(a)(ia) implications. However, the ITAT modified the PCIT's direction for blanket 30% disallowance of expenses, instructing the AO to verify whether TDS was required on daily wages and labor charges, allowing expenses below threshold limits. The Tribunal also confirmed the addition under s.50C as the difference between stamp duty value and sale consideration was 9.02%, exceeding the then-applicable tolerance limit of 5%. The assessee's appeal was partly allowed.
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