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 HC upheld the Principal Commissioner's suo motu revision under Section 263 of the Income Tax Act, allowing limited remand to the AO. The Court found the AO's rejection of the assessee's claims on seven of nine remitted points was without recorded reasons, rendering the order legally invalid. Emphasizing the mandatory requirement to provide reasoned orders, the Court held that absence of reasons violates principles of fairness and transparency, impeding effective judicial scrutiny and the assessee's right to know grounds for disallowance. Consequently, the impugned order was quashed, and the matter remanded to the AO for fresh adjudication of the seven points with proper reasoning and opportunity for hearing, directing completion within three months.
The HC upheld the Principal Commissioner's suo motu revision under Section 263 of the Income Tax Act, allowing limited remand to the AO. The Court found the AO's rejection of the assessee's claims on seven of nine remitted points was without recorded reasons, rendering the order legally invalid. Emphasizing the mandatory requirement to provide reasoned orders, the Court held that absence of reasons violates principles of fairness and transparency, impeding effective judicial scrutiny and the assessee's right to know grounds for disallowance. Consequently, the impugned order was quashed, and the matter remanded to the AO for fresh adjudication of the seven points with proper reasoning and opportunity for hearing, directing completion within three months.
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