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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ITAT dismissed the taxpayer's appeal against revision under section 263, upholding the PCIT's order. The tribunal found that the assessing officer (Ld. AO) had not demonstrated any application of mind to the treatment of "retention money," which the taxpayer had explained was not debited to profit and loss but adjusted in the income computation. The PCIT correctly noted absence of enquiry, verification or discussion in the assessment order regarding the retention money issue. Given the lack of cogent factual or legal analysis by the AO and the recorded failure of inquiry, the ITAT held the revision to be valid and found no merit in the taxpayer's contention that the PCIT's jurisdictional exercise was improper.
ITAT dismissed the taxpayer's appeal against revision under section 263, upholding the PCIT's order. The tribunal found that the assessing officer (Ld. AO) had not demonstrated any application of mind to the treatment of "retention money," which the taxpayer had explained was not debited to profit and loss but adjusted in the income computation. The PCIT correctly noted absence of enquiry, verification or discussion in the assessment order regarding the retention money issue. Given the lack of cogent factual or legal analysis by the AO and the recorded failure of inquiry, the ITAT held the revision to be valid and found no merit in the taxpayer's contention that the PCIT's jurisdictional exercise was improper.
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