SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
ITAT Ruling: Partially Allowed The ITAT partially upheld the Pr.CIT's revisionary order under section 263. The tribunal confirmed the Pr.CIT's finding regarding non-examination of unsecured loan transactions, specifically noting the AO's failure to verify the genuineness of loans from multiple parties and the absence of interest income reporting. However, the tribunal set aside the Pr.CIT's orders on TDS under section 194J and valuation of closing stock, determining that the AO's original assessment did not warrant revision. The key holdings emphasized procedural deficiencies in the original assessment while rejecting arbitrary revisionary powers that lack substantive evidence of revenue prejudice.
ITAT Ruling: Partially Allowed The ITAT partially upheld the Pr.CIT's revisionary order under section 263. The tribunal confirmed the Pr.CIT's finding regarding non-examination of unsecured loan transactions, specifically noting the AO's failure to verify the genuineness of loans from multiple parties and the absence of interest income reporting. However, the tribunal set aside the Pr.CIT's orders on TDS under section 194J and valuation of closing stock, determining that the AO's original assessment did not warrant revision. The key holdings emphasized procedural deficiencies in the original assessment while rejecting arbitrary revisionary powers that lack substantive evidence of revenue prejudice.
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TaxTMI 
TaxTMI 
