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 addressed reassessment proceedings under Section 148, finding the Assessing Officer's (AO) reasons to believe were valid based on information from the DIT(System). The tribunal rejected the assessee's argument of mere "change of opinion" and upheld the approval under Section 151 as independent and substantive. Regarding share transfer, the ITAT ruled against the AO's "look through approach" and invalidated the recharacterization of share sale as asset sale. The tribunal specifically held that Section 50CA could not be retrospectively applied for Assessment Year 2015-16, directing deletion of short-term capital gains additions. The appeal grounds relating to reassessment and valuation were partially allowed, with grounds 3-7 dismissed and grounds 12-18 allowed.
The ITAT addressed reassessment proceedings under Section 148, finding the Assessing Officer's (AO) reasons to believe were valid based on information from the DIT(System). The tribunal rejected the assessee's argument of mere "change of opinion" and upheld the approval under Section 151 as independent and substantive. Regarding share transfer, the ITAT ruled against the AO's "look through approach" and invalidated the recharacterization of share sale as asset sale. The tribunal specifically held that Section 50CA could not be retrospectively applied for Assessment Year 2015-16, directing deletion of short-term capital gains additions. The appeal grounds relating to reassessment and valuation were partially allowed, with grounds 3-7 dismissed and grounds 12-18 allowed.
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