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 revision order u/s 263 challenging validity of reassessment proceedings u/s 153A regarding computation of total income claiming interest u/s 24B. Tribunal held that Explanation 2 invoked by PCIT had no application as all relevant documents were filed by assessee during reassessment proceedings, which AO verified before finalizing assessment allowing interest claim u/s 24B. ITAT noted AO had previously allowed similar interest claim in AY 2012-13, establishing continuing cause of action that cannot be disturbed without different factual findings. Tribunal found PCIT's order reflected non-application of mind since AO had conducted adequate inquiries and examination of assessee's claims during both original and reassessment proceedings u/s 153A, taking plausible view not prejudicial to Revenue interests. Appeal allowed.
ITAT quashed PCIT's revision order u/s 263 challenging validity of reassessment proceedings u/s 153A regarding computation of total income claiming interest u/s 24B. Tribunal held that Explanation 2 invoked by PCIT had no application as all relevant documents were filed by assessee during reassessment proceedings, which AO verified before finalizing assessment allowing interest claim u/s 24B. ITAT noted AO had previously allowed similar interest claim in AY 2012-13, establishing continuing cause of action that cannot be disturbed without different factual findings. Tribunal found PCIT's order reflected non-application of mind since AO had conducted adequate inquiries and examination of assessee's claims during both original and reassessment proceedings u/s 153A, taking plausible view not prejudicial to Revenue interests. Appeal allowed.
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