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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SC dismissed the appeal, affirming the High Court's dismissal of Revenue's challenge to the reopening of assessment. The SC held that directions to place on record the reasons to believe and the original order under s.143(3) were intended to test correctness of the CIT and Tribunal findings; Revenue's inability to produce the records precluded any demonstration that those findings were perverse in relation to the objections. In consequence, absent the relevant material, the CIT's conclusions, as affirmed by the Tribunal, were not amenable to interference. Although the High Court could have refrained from observing that Revenue was uninterested in pursuing the appeal, that remark did not vitiate dismissal.
SC dismissed the appeal, affirming the High Court's dismissal of Revenue's challenge to the reopening of assessment. The SC held that directions to place on record the reasons to believe and the original order under s.143(3) were intended to test correctness of the CIT and Tribunal findings; Revenue's inability to produce the records precluded any demonstration that those findings were perverse in relation to the objections. In consequence, absent the relevant material, the CIT's conclusions, as affirmed by the Tribunal, were not amenable to interference. Although the High Court could have refrained from observing that Revenue was uninterested in pursuing the appeal, that remark did not vitiate dismissal.
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