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 PCIT's revisionary order under Section 263, finding no substantial errors in the original assessment. The tribunal held that the Assessing Officer (AO) had applied due diligence, considered all submitted documents, and reached plausible conclusions. The PCIT's directions for re-examination of various aspects including revenue recognition, financial expenses, house property income, and land transfer were deemed beyond jurisdictional scope. The tribunal emphasized that mere verification does not constitute an erroneous or prejudicial order, and the AO's original assessment was fundamentally sound. Consequently, all grounds raised by the assessee were allowed, effectively nullifying the PCIT's revisionary proceedings.
ITAT quashed PCIT's revisionary order under Section 263, finding no substantial errors in the original assessment. The tribunal held that the Assessing Officer (AO) had applied due diligence, considered all submitted documents, and reached plausible conclusions. The PCIT's directions for re-examination of various aspects including revenue recognition, financial expenses, house property income, and land transfer were deemed beyond jurisdictional scope. The tribunal emphasized that mere verification does not constitute an erroneous or prejudicial order, and the AO's original assessment was fundamentally sound. Consequently, all grounds raised by the assessee were allowed, effectively nullifying the PCIT's revisionary proceedings.
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