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 reassessment proceedings under Section 148 after finding the PCIT's approval was granted mechanically without proper application of mind, contrary to established precedent requiring judicial examination of relevant material. The tribunal identified variance between the AO's recorded reasons and PCIT's approval, rendering the notice invalid per Supreme Court guidance in Teleperformance Global. Regarding substantive issues, ITAT deleted additions for alleged unaccounted production based on electricity consumption variations, holding no evidence existed of off-books purchases or sales, and rejected the CIT(A)'s averaging methodology. The tribunal also deleted bogus purchase additions following Prime Steel Industries precedent, allowing the assessee's appeal entirely while dismissing the department's cross-appeal on all grounds.
ITAT quashed reassessment proceedings under Section 148 after finding the PCIT's approval was granted mechanically without proper application of mind, contrary to established precedent requiring judicial examination of relevant material. The tribunal identified variance between the AO's recorded reasons and PCIT's approval, rendering the notice invalid per Supreme Court guidance in Teleperformance Global. Regarding substantive issues, ITAT deleted additions for alleged unaccounted production based on electricity consumption variations, holding no evidence existed of off-books purchases or sales, and rejected the CIT(A)'s averaging methodology. The tribunal also deleted bogus purchase additions following Prime Steel Industries precedent, allowing the assessee's appeal entirely while dismissing the department's cross-appeal on all grounds.
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