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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The ITAT invalidated the assessment order due to procedural irregularities in jurisdictional transfer. The tribunal found that the assessment proceedings under Section 143(3) were initiated by one assessing officer but completed by another without a mandatory transfer order under Section 127. The tribunal disallowed capital gains deductions claimed by the appellant, observing that the transaction documents were self-manufactured, lacking genuine corroborative evidence. The ledger entries and unregistered agreements were deemed insufficient to substantiate the claimed expenses. Consequently, the assessment order was quashed for want of valid jurisdictional assumption, effectively nullifying the tax assessment.
The ITAT invalidated the assessment order due to procedural irregularities in jurisdictional transfer. The tribunal found that the assessment proceedings under Section 143(3) were initiated by one assessing officer but completed by another without a mandatory transfer order under Section 127. The tribunal disallowed capital gains deductions claimed by the appellant, observing that the transaction documents were self-manufactured, lacking genuine corroborative evidence. The ledger entries and unregistered agreements were deemed insufficient to substantiate the claimed expenses. Consequently, the assessment order was quashed for want of valid jurisdictional assumption, effectively nullifying the tax assessment.
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