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 held that the CIT(A) lacked jurisdiction to enhance the assessment under section 251 due to failure to issue the mandatory enhancement notice under section 251(2). The addition based on net profit at 8% of turnover was deleted as the assessee was not afforded an opportunity to respond to the enhancement proposal, rendering the addition invalid. Consequently, the addition relating to net profit was set aside, and the assessee's grounds were allowed.
The ITAT held that the CIT(A) lacked jurisdiction to enhance the assessment under section 251 due to failure to issue the mandatory enhancement notice under section 251(2). The addition based on net profit at 8% of turnover was deleted as the assessee was not afforded an opportunity to respond to the enhancement proposal, rendering the addition invalid. Consequently, the addition relating to net profit was set aside, and the assessee's grounds were allowed.
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