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 set aside the revisionary directions issued by the Pr. CIT under s.263 and allowed the assessee's appeal. The Tribunal held the AO's order, rendered after limited scrutiny to verify a large refund claim, was neither erroneous nor prejudicial to revenue; therefore the twin conditions for exercise of s.263 jurisdiction were not satisfied. The Pr. CIT's attempt to expand scrutiny by invoking Explanation 2 to s.263 was impermissible absent specific findings demonstrating any statutory condition in that Explanation was breached. The Pr. CIT failed to identify error of law or fact or want of verification by the AO; consequently the revision order was quashed and the s.263 direction set aside.
ITAT set aside the revisionary directions issued by the Pr. CIT under s.263 and allowed the assessee's appeal. The Tribunal held the AO's order, rendered after limited scrutiny to verify a large refund claim, was neither erroneous nor prejudicial to revenue; therefore the twin conditions for exercise of s.263 jurisdiction were not satisfied. The Pr. CIT's attempt to expand scrutiny by invoking Explanation 2 to s.263 was impermissible absent specific findings demonstrating any statutory condition in that Explanation was breached. The Pr. CIT failed to identify error of law or fact or want of verification by the AO; consequently the revision order was quashed and the s.263 direction set aside.
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