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 allowed the appellant's appeal, holding that the reopening of assessment beyond four years was invalid as no fresh material justified it, given that the Tax Audit Report was available to the AO from the outset, negating any failure to disclose material as required under Section 148. Consequently, the reassessment was quashed. Regarding depreciation, the Tribunal held that the appellant, having acquired ownership and use of the asset within the first half of the relevant fiscal year, was entitled to full depreciation rather than the 50% allowed by the AO. The AO's disallowance of part depreciation was reversed, as both ownership and usage criteria were met for more than 180 days. Thus, the appellant succeeded on both grounds, resulting in the deletion of the addition and dismissal of the reassessment proceedings.
The ITAT allowed the appellant's appeal, holding that the reopening of assessment beyond four years was invalid as no fresh material justified it, given that the Tax Audit Report was available to the AO from the outset, negating any failure to disclose material as required under Section 148. Consequently, the reassessment was quashed. Regarding depreciation, the Tribunal held that the appellant, having acquired ownership and use of the asset within the first half of the relevant fiscal year, was entitled to full depreciation rather than the 50% allowed by the AO. The AO's disallowance of part depreciation was reversed, as both ownership and usage criteria were met for more than 180 days. Thus, the appellant succeeded on both grounds, resulting in the deletion of the addition and dismissal of the reassessment proceedings.
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