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 ruled in favor of the assessee, setting aside the Pr. CIT's order under Section 263. The tribunal found that the Assessing Officer (AO) had conducted a proper inquiry and accepted the assessee's documentary evidence regarding the land's distance from municipal limits. The Pr. CIT's attempt to reexamine the issue based on a 2024 Google map verification was deemed inappropriate, particularly given municipal limit changes in 2016. The tribunal emphasized that when the AO has already satisfied himself with the supporting evidence, the CIT cannot remand the matter for fresh adjudication merely due to uncertainty about the claim's correctness.
ITAT ruled in favor of the assessee, setting aside the Pr. CIT's order under Section 263. The tribunal found that the Assessing Officer (AO) had conducted a proper inquiry and accepted the assessee's documentary evidence regarding the land's distance from municipal limits. The Pr. CIT's attempt to reexamine the issue based on a 2024 Google map verification was deemed inappropriate, particularly given municipal limit changes in 2016. The tribunal emphasized that when the AO has already satisfied himself with the supporting evidence, the CIT cannot remand the matter for fresh adjudication merely due to uncertainty about the claim's correctness.
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