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 dismissed the Revenue's appeal regarding rectification u/s 154, finding no prima facie mistake apparent from records. The tribunal concluded that the deduction u/s 80IA(12A) was comprehensively examined by CIT(A), and the provisions of section 154 could not be invoked to modify the assessee's claim. The AO was not justified in withdrawing the deduction claim under section 80IA(2A), and both legal grounds and case merits supported dismissal of the Revenue's appeal.
ITAT dismissed the Revenue's appeal regarding rectification u/s 154, finding no prima facie mistake apparent from records. The tribunal concluded that the deduction u/s 80IA(12A) was comprehensively examined by CIT(A), and the provisions of section 154 could not be invoked to modify the assessee's claim. The AO was not justified in withdrawing the deduction claim under section 80IA(2A), and both legal grounds and case merits supported dismissal of the Revenue's appeal.
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