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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The ITAT held that the PCIT's revision under s.263 was unsustainable and quashed the revisionist order, affirming the assessment as not erroneous or prejudicial to Revenue. The AO had made appropriate enquiries, verified receipts and bank statements, and taken a plausible view; no incriminating material directly connecting the assessee's donations to a bogus donation racket was placed on record. The Tribunal found no specific enquiry left undone by the AO and observed that, if relevant incriminating material existed, Revenue's remedy was reopening under s.148 rather than s.263. The PCIT impermissibly substituted his opinion for the AO's within the limited scope of s.263; appeal allowed.
The ITAT held that the PCIT's revision under s.263 was unsustainable and quashed the revisionist order, affirming the assessment as not erroneous or prejudicial to Revenue. The AO had made appropriate enquiries, verified receipts and bank statements, and taken a plausible view; no incriminating material directly connecting the assessee's donations to a bogus donation racket was placed on record. The Tribunal found no specific enquiry left undone by the AO and observed that, if relevant incriminating material existed, Revenue's remedy was reopening under s.148 rather than s.263. The PCIT impermissibly substituted his opinion for the AO's within the limited scope of s.263; appeal allowed.
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