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 quashed the assessment order under sections 153A/153C, finding the Joint Commissioner of Income Tax's approval mechanically granted without substantive application of mind. The tribunal determined that the approval process cannot be a mere formality and must involve judicious quasi-judicial consideration of incriminating materials. The approval's lack of meaningful merit evaluation rendered it legally invalid, consequently invalidating the entire assessment proceedings. The assessee's appeal was allowed, effectively nullifying the assessment order due to procedural impropriety in the approval mechanism.
ITAT quashed the assessment order under sections 153A/153C, finding the Joint Commissioner of Income Tax's approval mechanically granted without substantive application of mind. The tribunal determined that the approval process cannot be a mere formality and must involve judicious quasi-judicial consideration of incriminating materials. The approval's lack of meaningful merit evaluation rendered it legally invalid, consequently invalidating the entire assessment proceedings. The assessee's appeal was allowed, effectively nullifying the assessment order due to procedural impropriety in the approval mechanism.
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