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 held that the Pr. CIT's revision under s. 263 challenging an assessment passed under s. 153A read with s. 143(3) in respect of carbon-credit receipts failed because the incriminating materials relied on by the AO were held by the CIT(A) to be non-incriminating, thereby vitiating the foundation for reassessment; the assessee's appeal on this limb was allowed. Conversely, ITAT upheld the Pr. CIT's exercise of s. 263 jurisdiction to rectify erroneous computation of deduction under s. 80IA where the AO omitted allocation of head-office expenses and other costs, causing prejudice; such specific apportionment fell within "such matters" warranting revision, and the assessee's appeal on this issue was dismissed.
ITAT held that the Pr. CIT's revision under s. 263 challenging an assessment passed under s. 153A read with s. 143(3) in respect of carbon-credit receipts failed because the incriminating materials relied on by the AO were held by the CIT(A) to be non-incriminating, thereby vitiating the foundation for reassessment; the assessee's appeal on this limb was allowed. Conversely, ITAT upheld the Pr. CIT's exercise of s. 263 jurisdiction to rectify erroneous computation of deduction under s. 80IA where the AO omitted allocation of head-office expenses and other costs, causing prejudice; such specific apportionment fell within "such matters" warranting revision, and the assessee's appeal on this issue was dismissed.
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