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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT held that the reopening of assessment u/s. 147 was invalid because the AO relied only on unspecified "information" from an internal portal without furnishing the actual material or reasons to the assessee, thereby failing to demonstrate subjective satisfaction or provide the basis for reopening. The AO did not correlate the undisclosed information with the assessee's transactions nor elicit statements based on that information. Consequently, additions u/s. 68 were untenable: the assessee produced purchase particulars, demat records and exchange sale documents which the AO neither controverted nor discredited in the assessment order. For these reasons the ITAT set aside the reopening and allowed the assessee's appeal.
ITAT held that the reopening of assessment u/s. 147 was invalid because the AO relied only on unspecified "information" from an internal portal without furnishing the actual material or reasons to the assessee, thereby failing to demonstrate subjective satisfaction or provide the basis for reopening. The AO did not correlate the undisclosed information with the assessee's transactions nor elicit statements based on that information. Consequently, additions u/s. 68 were untenable: the assessee produced purchase particulars, demat records and exchange sale documents which the AO neither controverted nor discredited in the assessment order. For these reasons the ITAT set aside the reopening and allowed the assessee's appeal.
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