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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HC upheld ITAT's decision setting aside PCIT's order under Section 263, finding that PCIT failed to establish a prima facie opinion of assessment order being erroneous or prejudicial to revenue. The court emphasized that before modifying an assessment, PCIT must conduct necessary inquiries and consider the assessee's submitted replies. Merely alleging lack of investigation without specifying deficiencies does not justify reassessment. The ITAT's order was deemed legally sound, as the AO had already verified documents, investors' identities, and fund sources during original assessment proceedings.
HC upheld ITAT's decision setting aside PCIT's order under Section 263, finding that PCIT failed to establish a prima facie opinion of assessment order being erroneous or prejudicial to revenue. The court emphasized that before modifying an assessment, PCIT must conduct necessary inquiries and consider the assessee's submitted replies. Merely alleging lack of investigation without specifying deficiencies does not justify reassessment. The ITAT's order was deemed legally sound, as the AO had already verified documents, investors' identities, and fund sources during original assessment proceedings.
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