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 reopening under sections 147/148 and the section 148A notice were invalid as issued on the same facts and documents already verified during original assessment, constituting a prohibited change of opinion; no new material was brought on record by the AO to sustain reopening. The Tribunal also deleted the addition under section 43CA, finding the stamp duty value-agreement value variance below the 5% margin applicable to AY 2016-17, and directed the AO to delete the impugned addition. Grounds raised by the Assessee in respect of the reopening and the section 43CA addition were allowed.
ITAT held that the reopening under sections 147/148 and the section 148A notice were invalid as issued on the same facts and documents already verified during original assessment, constituting a prohibited change of opinion; no new material was brought on record by the AO to sustain reopening. The Tribunal also deleted the addition under section 43CA, finding the stamp duty value-agreement value variance below the 5% margin applicable to AY 2016-17, and directed the AO to delete the impugned addition. Grounds raised by the Assessee in respect of the reopening and the section 43CA addition were allowed.
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