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 allowed the appeal and set aside the PCIT's revisionary order under section 263. The Tribunal held that jurisdiction under section 263 requires both a demonstrable error in the AO's order and that the order be prejudicial to Revenue; absent either, revision cannot be validly exercised. PCIT conceded there was no error in the assessment concerning the assessee's claim of deduction under section 80G read with section 115BAA, and the AO had reached a plausible, lawful view after considering the assessee's submissions. Consequently, no error or prejudice was established and the impugned section 263 order was unsustainable in law.
ITAT allowed the appeal and set aside the PCIT's revisionary order under section 263. The Tribunal held that jurisdiction under section 263 requires both a demonstrable error in the AO's order and that the order be prejudicial to Revenue; absent either, revision cannot be validly exercised. PCIT conceded there was no error in the assessment concerning the assessee's claim of deduction under section 80G read with section 115BAA, and the AO had reached a plausible, lawful view after considering the assessee's submissions. Consequently, no error or prejudice was established and the impugned section 263 order was unsustainable in law.
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