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 set aside the PCIT's revision order under section 263, holding that the AO's assessment under sections 143(3) read with 144B was not erroneous or prejudicial to the Revenue. The tribunal found the deduction claimed under section 80G for donations made as part of CSR expenditure to approved trusts was allowable, rejecting the PCIT's contention of inadequate inquiry. Further, the claim for deduction of "GST Credit Expenses Written Off" under section 37(1) was upheld, as the AO had conducted sufficient examination and formed a plausible view. The PCIT's disagreement did not satisfy the pre-condition for invoking revisionary jurisdiction, and mere difference of opinion could not justify fresh assessment.
The ITAT set aside the PCIT's revision order under section 263, holding that the AO's assessment under sections 143(3) read with 144B was not erroneous or prejudicial to the Revenue. The tribunal found the deduction claimed under section 80G for donations made as part of CSR expenditure to approved trusts was allowable, rejecting the PCIT's contention of inadequate inquiry. Further, the claim for deduction of "GST Credit Expenses Written Off" under section 37(1) was upheld, as the AO had conducted sufficient examination and formed a plausible view. The PCIT's disagreement did not satisfy the pre-condition for invoking revisionary jurisdiction, and mere difference of opinion could not justify fresh assessment.
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