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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The HC held that the revisional authority under Section 264 is competent to rectify bona fide errors committed by the assessee in the return, even after the time for filing a revised return has expired. The impugned order was quashed for erroneously refusing to permit reliance on disclosures related to the profit and loss account on the ground that only the assessee can alter the return particulars. The Court emphasized that jurisdiction under Section 264 extends to correcting mistakes by the assessee and remanded the matter for fresh consideration in accordance with this principle. The prior refusal to exercise jurisdiction was held to be an error warranting interference.
The HC held that the revisional authority under Section 264 is competent to rectify bona fide errors committed by the assessee in the return, even after the time for filing a revised return has expired. The impugned order was quashed for erroneously refusing to permit reliance on disclosures related to the profit and loss account on the ground that only the assessee can alter the return particulars. The Court emphasized that jurisdiction under Section 264 extends to correcting mistakes by the assessee and remanded the matter for fresh consideration in accordance with this principle. The prior refusal to exercise jurisdiction was held to be an error warranting interference.
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