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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT set aside the revision order passed by the PCIT under section 263, finding multiple procedural and substantive infirmities. The PCIT violated principles of natural justice by failing to serve show-cause notices and denying the assessee an opportunity to be heard. The notices were not available on the Income Tax portal, indicating non-service. Additionally, the PCIT erroneously relied on figures pertaining to a sister concern rather than the assessee, leading to incorrect cancellation of the assessment order. The revision order was thus based on flawed facts, lacked proper application of mind, and was prejudicial to the assessee. The ITAT held that the Pr. CIT failed to establish that the assessment order was erroneous or prejudicial to revenue interests under section 263. Consequently, the appeal was allowed, and the revision order was quashed.
The ITAT set aside the revision order passed by the PCIT under section 263, finding multiple procedural and substantive infirmities. The PCIT violated principles of natural justice by failing to serve show-cause notices and denying the assessee an opportunity to be heard. The notices were not available on the Income Tax portal, indicating non-service. Additionally, the PCIT erroneously relied on figures pertaining to a sister concern rather than the assessee, leading to incorrect cancellation of the assessment order. The revision order was thus based on flawed facts, lacked proper application of mind, and was prejudicial to the assessee. The ITAT held that the Pr. CIT failed to establish that the assessment order was erroneous or prejudicial to revenue interests under section 263. Consequently, the appeal was allowed, and the revision order was quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
