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 held that the assessment order under sec. 153C was invalid due to lack of proper satisfaction regarding incriminating material. The AO failed to establish a direct correlation between search materials and the assessee's income for AY 2019-2020. Consequently, the PCIT's revisionary order under sec. 263 was deemed illegal and void ab initio. The tribunal emphasized that an illegal assessment order cannot be legitimized through revisionary powers. The order was ultimately decided in favor of the assessee, quashing both the assessment order and the revisionary proceedings.
ITAT held that the assessment order under sec. 153C was invalid due to lack of proper satisfaction regarding incriminating material. The AO failed to establish a direct correlation between search materials and the assessee's income for AY 2019-2020. Consequently, the PCIT's revisionary order under sec. 263 was deemed illegal and void ab initio. The tribunal emphasized that an illegal assessment order cannot be legitimized through revisionary powers. The order was ultimately decided in favor of the assessee, quashing both the assessment order and the revisionary proceedings.
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