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...
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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 AO's order was not erroneous or prejudicial to the revenue despite no addition being made for accommodation entries following reopening under section 147. The AO had duly examined and verified the issues during reassessment and found no grounds for addition. The PCIT's revision under section 263, asserting the AO's order was erroneous, was therefore unjustified. The Tribunal set aside the PCIT's order and allowed the assessee's appeal, affirming that absence of addition does not automatically render the AO's order erroneous if the matter was properly considered during reassessment.
The ITAT held that the AO's order was not erroneous or prejudicial to the revenue despite no addition being made for accommodation entries following reopening under section 147. The AO had duly examined and verified the issues during reassessment and found no grounds for addition. The PCIT's revision under section 263, asserting the AO's order was erroneous, was therefore unjustified. The Tribunal set aside the PCIT's order and allowed the assessee's appeal, affirming that absence of addition does not automatically render the AO's order erroneous if the matter was properly considered during reassessment.
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